The Council on Governmental Relations (COGR), representing over 220 U.S. research universities and institutes, submitted formal comments to the U.S. Department of Health and Human Services (HHS) regarding the department’s interim final rule implementing the updated Office of Management and Budget (OMB) Uniform Guidance. COGR acknowledged the complexity of HHS’s dual-phased implementation—initial adoption of certain provisions on October 1, 2024, with comprehensive compliance required by October 1, 2025—and recognized the challenges faced by both the agency and grantees in adapting to staggered federal requirements. While COGR appreciated the intent to reduce administrative burden, especially through increased equipment and subaward thresholds, they flagged that the process introduces complications for awards spanning different effective dates and for institutions governed by state-level policies.
COGR recommended that HHS amend all pre-October 1, 2024 awards to permit earlier adoption of higher thresholds, in alignment with financial statement practices, and urged support from the Cost Allocation Services for prompt implementation of these changes. They also highlighted the importance of further stakeholder engagement prior to the final implementation date to ensure a smoother transition and mitigating any unintended administrative challenges. The organization reaffirmed its commitment to constructive collaboration with HHS to ensure efficient, effective implementation that benefits both federal agencies and research institutions.
