The Council on Governmental Relations (COGR) Phase I Report evaluates the financial and administrative burdens imposed on U.S. research institutions by recent federal research security disclosure requirements designed to mitigate inappropriate foreign influence. Drawing responses from 26 institutions (22 mid-to-large, 4 smaller), the 2022-2023 survey systematically quantifies the costs incurred in the first year of compliance (“Year One”) with disclosure mandates from NIH, NSF, and OSTP. These requirements obligate principal investigators and key personnel to fully disclose all sources of research support, affiliations, in-kind contributions, and relevant financial interests, with institutions responsible for certifying compliance and ensuring appropriate training and IT infrastructure.
The report’s findings are significant: average year one compliance costs are estimated at over $100,000 for smaller institutions and more than $400,000 for mid-sized and large institutions, with a projected total exceeding $50 million for the largest 116 research universities alone. Major cost drivers include new personnel, opportunity costs from reallocated staff time, investments in information technology, and extensive preparation and training efforts. Smaller institutions, with less developed compliance infrastructure, face a proportionally higher burden, risking their participation in federally funded research and complicating federal diversification goals. At present, these costs are largely borne by the institutions themselves, as existing federal reimbursement structures—capped at 26% for administrative costs—do not allow meaningful recoupment. COGR recommends enhanced federal-institutional cost sharing, harmonization of requirements across agencies to reduce burden, and ongoing stakeholder engagement to assess cost effectiveness and potential unintended consequences, such as reduced international scientific collaboration. The report emphasizes that without clear federal action on equitable cost allocation, growing compliance demands may impede research productivity and the inclusion of emerging institutions in the national research enterprise.
COGR conducted Phase I of the survey described in this report to quantify the considerable time and resources (financial and otherwise) that research institutions have invested (or will invest) to achieve compliance with the Disclosure Requirements. COGR is providing this Phase I report to research institutions and federal research funding agencies in the hope that it will both encourage and facilitate discussions of equitable cost allocation, as well as how “return on investment” (ROI) should be considered and measured.
