Financial Management & Compliance

June 28, 2024

COGR Responds to OMB's Invitation to Provide Comments and Technical Corrections to Address Select Items in the Recently Released OMB Guidance for Federal Financial Assistance - read more...


May 16, 2024

Slides & Recording Now Available (Log In Required): A Second Look at the Final OMB Guidance for Federal Financial Assistance - read more...


December 4, 2023

COGR Responds to OMB's NPRM on Guidance for Grants & Agreements "Uniform Guidance" - read more...


September 29, 2023

Session Materials Available: Workshop on Compliance with Research Security Requirements and the Associated Cost of Compliance Survey - read more...


On September 27, 2023, COGR is hosted a virtual, interactive workshop to provide an opportunity for members to share information on institutional efforts to comply with research security requirements and how to assess associated costs and institutional burden.  The workshop was led by COGR directors and members of COGR’s four committees.

NSTC is expected to finalize its model disclosure forms and research security program standards this autumn, and upon their issuance, COGR will initiate Phase II of its research security cost survey.  This workshop provided a forum for institutions to discuss their compliance strategies, learn about the methodology of the Phase II survey, and consider the resources they will need to implement research security programs and additional disclosure requirements.  The workshop begins with an overview of current requirements and the Phase II survey, and then participants joined break-out rooms to discuss how their institutions are addressing certification mandates, training requirements, security program structures and associated costs and administrative burden. 

Institutions that participated in the Workshop will be highly encouraged to complete the Phase II Survey.  Phase II will be initiated later this autumn, and COGR will follow-up with workshop participants at the time to determine if they will participate.  

Questions and topics of interest may be sent in advance of the session to Kristin West at

Workshop materials include:

Session recording (log in required)
Slide Presentation
Institutional Resources on Research Security (log in required)


July 21, 2023

COGR Responds to OMB's Request to Provide Data-driven Evidence to Support Modifications to 2 CFR Chapter 2, Part 200 (2 CFR 200) of the Uniform Guidance (UG) - read more...


June 5, 2023

COGR Participates in Joint Association Response to Comment Request; Agency Information Collection Activities; Submission to OMB for Review and Approval; Foreign Gifts and Contracts Disclosures - read more...


May 11, 2023

Results from the COGR Survey on the Cost of Complying with the New NIH DMS Policy - read more...


March 14, 2023

COGR Responds to OMB's RFI: Uniform Guidance (2 CFR 200) - read more...

COGR has posted its Letter to OMB, in response to OMB’s Request for Information (RFI) – Uniform Guidance. We expect OMB to review responses from all stakeholders and publish proposed revisions to the Uniform Guidance later in 2023. Contact Krystal Toups at or David Kennedy at if you have comments or questions


March 10, 2023

COGR Posts DRAFT Response to OMB (Uniform Guidance) - read more...


March 2, 2023

COGR's 2 CFR 200 "Uniform Guidance" Resource Page - read more...


February 21, 2023

COGR Submits Comments to GSA Regarding the Transition of the Federal Audit Clearinghouse - read more...

COGR provided comments to the GSA regarding the transition of the Federal Audit Clearinghouse from the U.S. Census Bureau to the GSA.


February 21, 2023

COGR Requests a 30-Day Extension to Respond to OMB's RFI - read more...

COGR requested a 30-day extension to respond to OMB’s RFI regarding updates to 2 CFR Part 200, Uniform Guidance.


February 15, 2023

COGR's NIH Data Management and Sharing Readiness Guide: Chapter 4 Part II, Project-Based and Institutional Cost Considerations - Budgeting & Costing - read more...


February 15, 2023

COGR Releases NIH DMS Readiness Guide Chapter 4 Part II - Budgeting and Costing: Project-Based and Institutional Cost Considerations - read more...


November 8, 2022

Chapter 3 Part II of COGR's NIH DMS Readiness Guide: Roles and Responsibilities (Excel Download) Now Available - read more...


September 29, 2022

COGR & the Association of Research Libraries Present: Gearing Up for January 2023: Institutional Strategies for Implementing the NIH Data Management & Sharing Policy - read more...


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


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


January 27, 2020

COGR's Response to JCORE RFI -

Posted January 27, 2020

This letter contains COGR's comments in response to the request for information on aspects of the American Research Environment [FR Doc. 2019-25604]


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 -

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 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


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 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 -

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

This letter provides joint association comments on Department of Energy regulations, paperwork requirements and other regulatory obligations as part of the agency’s implementation of Executive Order 13771, “Reducing Regulation and Controlling Regulatory Costs.” 


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 -

“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



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


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.


October 21, 2014

COGR Survey and the Role of the DS-2 - read more...


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


March 1, 2007

Compensation, Effort Commitments and Certification

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


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