COGR Responds to NIH Proposed Collection of Post-Award Reporting Requirements

COGR submitted a formal response to the National Institutes of Health (NIH) regarding proposed post-award reporting requirements for Data Management and Sharing Plans within the Research Performance Progress Report (RPPR). COGR’s comments primarily focus on section C.5.c of the RPPR, offering targeted suggestions to enhance the clarity, utility, and efficiency of the data collection process. Specific recommendations include revising ambiguous response options to better indicate the applicability of the 2023 NIH Final Data Management and Sharing (DMS) Policy, eliminating duplicative questions, and streamlining data entry through dropdown menus and rollover features for recurring information. Additionally, COGR suggests modifications to terminology—such as broadening definitions around repositories and unique identifiers—to reflect practical constraints faced by researchers. The organization also recommends removing redundant references to data sharing from unrelated sections to prevent confusion. COGR underscores the importance of clear, non-redundant instructions for researchers to facilitate accurate compliance and reporting. The response reflects a commitment to ensuring that federal reporting requirements support transparency and accountability while minimizing unnecessary administrative burden. COGR expresses its willingness to continue collaborating with NIH to refine these processes, emphasizing that improved clarity and consistency in reporting mechanisms will benefit both the research community and federal oversight objectives.