Financial Management & Compliance

June 30, 2022

COGR Submits Comments to OMB Regarding the 2022 Compliance Supplement - read more...

 

April 21, 2022

COGR Submits Comments to NASA on T&C's Affecting Procurement - read more...

 

December 15, 2021

UPDATE & ERRATA TO COGR NOVEMBER 2021 UPDATE - read more...

Posted December 15, 2021

 

November 8, 2021

COGR Submits Comments to DoEd on HEERF Data Collection Form Federal Register Notice - read more...

Posted November 8, 2021

 

August 30, 2021

COGR Submits Comments to OMB on 2 CFR 200 Subpart F - Audit Requirements Appendix XI - Compliance Supplement 2021 - read more...

 

August 12, 2021

COGR Submits Letter to DoEd in Response on HEERF I, II, & III, Data Collection Form - read more...

Posted August 12, 2021

 

May 14, 2021

COGR Writes to NSF to Address Concerns on Recent Audit Findings Related to Application of the F&A Cost Rate - read more...

Posted on May 14, 2021

 

April 21, 2021

F&A Cost Rates and Reimbursement Pressures Under COVID-19: Maintaining a Fair and Reliable System - read more...

Posted April 21, 2021

 

August 25, 2020

Research Impact Under COVID-19: Financial Crisis and the "Pandemic Normal" - read more...

Posted August 25, 2020

 

May 8, 2020

Furlough Programs and Implications for Financial Research Compliance (Updated) - read more...

Posted May 8, 2020

 

February 7, 2020

2 CFR 200 (Uniform Guidance) - read more...

Click here

 

January 27, 2020

COGR's Response to JCORE RFI - read more...

Posted January 27, 2020

 

January 23, 2020

COGR Letter to NIFA Regarding the Reimagining NIFA Initiative - read more...

Posted January 23, 2020

 

July 26, 2019

COGR Letter to OMB on 2019 Compliance Supplement - read more...

Posted July 26, 2019

 

April 12, 2019

COGR Releases "Excellence in Research: The Funding Model, F&A Reimbursement, and Why the System Works" - read more...

Posted April 12, 2019

Additional F&A Resources

 

March 21, 2019

HERD Survey Questions from COGR - read more...

Posted 3/21/19

 

October 20, 2017

COGR Submits Letter to OMB on Payments/Reimbursements under Single Audit - read more...

*As Sent to COGR Listserv 10/20:

 

COGR has sent the following letter to Gilbert Tran at OMB.

 

Some of your institutions have been challenged in recent single audits. Specifically, a new auditor position is that prior to billing a federal sponsor for reimbursement, the institution must have evidence that the institution’s payment to the vendor has been cleared by the institution’s bank. This is in conflict with existing policy per 2 CFR Part 200.305(b): … payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.

 

Public Comments are due October 31, 2017. The COGR letter to OMB and Mr. Tran is attached. We encourage you to submit a letter if this issue is a concern at your institution. A letter in support of the COGR letter, with any examples specific to your institution, is appropriate.

 

DIRECTIONS FOR SUBMITTING LETTERS:  As specified in an August 14th Federal Register Notice, comments should be submitted to Gilbert Tran at hai_m._tran@omb.eop.gov. Include “2 CFR Part 200.305, Subpart F-Audit Requirements, Appendix XI-Compliance Supplement-2017” in the subject line and the full body of your comments in the text of the email and as an attachment. Include your name, title, organization, postal address, telephone number, and email address in the text of the message. Comments may also be sent through regulations.gov.

 

This is an important issue to a number of institutions and comment letters from your institution, in addition to the COGR letter, will elevate the unease around this issue. Contact David Kennedy at dkennedy@cogr.edu if you have questions on how to best craft your concerns to OMB.

 

August 24, 2017

Recommendations for HHS and NIH Research Regulatory Reform - read more...

 

August 24, 2017

Discussion Points on Facilities and Administrative Costs and Regulatory Reform - read more...

 

August 24, 2017

Associations Oppose Cuts to NIH Budget - read more...

COGR joined with over 100 other organizations Monday on a letter to Office of Management and Budget Director Mick Mulvaney and Health and Human Services Secretary Tom Price to oppose the proposed cuts to NIH funding and facilities and administrative (F&A) costs in the Administration's FY18 budget. 

Among other things, the letter states that "If the Administration’s proposal to reduce NIH support for F&A moves forward, it will make research unaffordable for many institutions and ultimately lead to less research carried out across the country", and that "the economic impact could also be significant; communities will lose jobs, and the country will fall behind as our foreign competitors forge ahead in medical research. These consequences will hurt patients, scientists, and all Americans."

 

July 14, 2017

COGR Submits Joint Association Letter on DOE Regulatory Reform - read more...

Posted July 14, 2017

 

June 12, 2017

COGR Letter to Mulvaney and Price Objecting to NIH and F&A Budget Cuts - read more...

Posted June 12, 2017

 

April 17, 2017

At OMB Request: Letter to Identify OMB Actions to Reduce Administrative Burden - read more...

Posted April 17, 2017

 

March 29, 2017

COGR Submits Letter to OMB to Address 2017 Compliance Supplement and Securing Student Information - read more...

The National Association of College and University Business Officers (NACUBO), EDUCAUSE, the National Association of Student Financial Aid Administrators (NASFAA), and COGR write to OMB to address a proposed new section to the 2017 Compliance Supplement: Securing Student Information, Student Financial Aid (SFA) Cluster.

Click here.

 

March 1, 2017

F&A Survey Results Available to COGR Membership

Click here.

 

February 7, 2017

Finances of Research Universities - June 2014 - read more...

“Finances of Research Universities” describes the financial landscape of research universities and calls for active collaboration among all stakeholders to address financial risks to the research enterprise in a productive manner.

Full Report

Summary

 

December 1, 2016

An Analysis of the DCA Best Practices Manual - COGR Interpretations

Click here to view the paper.

 

August 8, 2016

Faculty Appointments at Academic Medical Centers - A Focus on University and Veterans Joint Appointments

Click here to view
 

 

March 1, 2016

Compensation, Effort Commitments and Certification

Click here to view the full document.
Click here to view the Executive Overview.

 

January 1, 2016

How to Conduct Non-Federal Stem Cell Research Without Violating the Federal Stem Cell Funding Prohibition

How to Conduct Non-Federal Stem Cell Research Without Violating the Federal Stem Cell Funding Prohibition
By Robert J. Kenny, Jr. [Medical Research Law and Policy Review, 2005]

National Institutes of Health Stem Cell Resource Web Site

 

September 4, 2015

Letter to Department of Labor on "Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees"

Click here to view

 

July 1, 2015

COGR Guide to 2 CFR 200.430 Compensation-Personal Services

Click here for the Guide.

 

December 16, 2014

COGR Readiness Document - Uniform Guidance -

Click here for the Guide. If interested in a Word version of the Guide, please contact David Kennedy.

 

May 2, 2012

COGR Response to Grants Reform

OMB Advance Notice of Proposed Guidance, April 2012. Click here for the letter.

 

November 14, 2011

COGR Proposal to the A-21 Task Force

Discontinuation of the Effort Reporting Requirement, November 2011. Click here for the proposal.

 

July 28, 2011

COGR Response to NIH RFI

 Input on Reduction of Cost and Burden Associated with Federal Cost Principles for Educational Institutions (OMB Circular A-21), July 2011.  Click here to view the Letter and here to view the Attachment.

 

January 1, 2011

Regulatory and Financial Reform of Federal Research Policy - Recommendations to the NRC

Click here to view the Recommendations.

 

November 1, 2010

Federal Funding Agency Limitations on Cost Reimbursement: A Request for Consistency in the Application of Federal Guidelines

Click here to view the Policy Paper
Click here to view the Appendix

 

June 1, 2005

Cost and Facility Issues in Conducting Stem Cell Research

Summary of June 2005 COGR Meeting Discussion

 

November 1, 2001

Managing Externally Funded Programs at Colleges and Universities: A Guideline to Good Management Practices

Click here to view