Other Research Compliance

March 27, 2024

COGR Responds to APHIS Notice of Proposed Rulemaking on Agricultural Bioterrorism Protection Act of 2002; Biennial Review and Republication of the Select Agent and Toxin List - read more...


March 27, 2024

COGR Submits Response to CDC on Notice of Proposed Rulemaking on Possession, Use, and Transfer of Select Agents and Toxins; Biennial Review of the List of Select Agents and Toxins - read more...


February 16, 2024

Update Now Available: Quick Reference Table of Current & Upcoming Federal Research Security Requirements - read more...


February 16, 2024

Quick Reference Table of Current & Upcoming Federal Research Security Requirements - read more...


January 31, 2024

COGR Letter to OEI HHS-OIG -


January 31, 2024

COGR Comments & Extension Request to Office of Evaluation and Inspections, OIG, HHS on NIH Monetary Donations that Support Research Survey (OEI-03-22-00570) - 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 kwest@cogr.edu.

Workshop materials include:

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


July 8, 2023

Overview of Department of Defense Statement on Countering Unwanted Foreign Influence in Department-Funded Research Institutions of Higher Education - read more...


February 27, 2023

COGR Signs on to Multi-Association Letter to DoEd Regarding Foreign Gift & Contract Disclosures (ED-2022-SCC-0159) - read more...


November 14, 2022

Research Security and the Cost of Compliance – Phase I Report, Disclosure Requirements Now Available - read more...

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.


November 8, 2022

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


October 31, 2022

COGR Letter for Request for Comment for Common Disclosure Forms - read more...


October 21, 2022

NSPM-33 Implementation Guidance Disclosure Requirements Standardization Talking Points for Institutions - read more...

The proposed Standardized Disclosure Forms were released for public comment on August 31, 2022. This document includes critical themes for institutions to consider. These themes were included in the COGR response


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...


September 23, 2022

Overview of the NSPM-33 Standardization Disclosure Forms for the Common Biographical Sketch and Current and Pending (Other) Support 9/23 Webinar Materials - read more...

The highly anticipated Standardize Disclosure Forms were released on August 31, 2022 for public comment. Section 4(b)(vi) of NSPM-33 directs that “agencies should standardize forms for initial disclosures as well as annual updates…and should provide clear instructions to accompany these forms and to minimize any associated administrative burden”. This webinar provides an overview of the standardized disclosure forms and associated attributes highlighting key considerations for institutions.

Speakers for this webinar are Pamela Webb, Associate Vice President for Research, University of Minnesota; Jeffrey Friedland, Associate Vice President, Research Administration; University of Delaware; Craig Reynolds Assistant Vice President for Research - Sponsored Projects University of Michigan; and Krystal Toups, Director, Contracts & Grants Administration. This webinar provides information on how institutions can engage and provide comments by October 31, 2022. 


September 7, 2022

COGR Matrix of Laws, Regulations, and Policies Regarding Science & Security - read more...

COGR has developed a comprehensive chart that summarizes and compares federal laws, regulations, and policies in the area of science and security.  The chart is divided into three separate tabs that cover (a) major federal-wide legislation or policy (e.g., National Presidential Security Memorandum 33, CHIPS and Science Act of 2022); (b) agency disclosure requirements for researchers and research institutions; and (c) agency conflict of interest policies.  The chart will be updated as new laws, policy and guidance are published. 


August 30, 2022

COGR Submits Comments to OHRP in Response to HHS-OASH-2022-0011 "Use of a Single IRB for Cooperative Research" Draft Guidance - read more...


August 11, 2022

Looking at the CHIPS on the Table Webinar Materials - read more...

The CHIPS and Science Act of 2022 is expected to have a major impact on numerous facets of the U.S. science and technology landscape, including manufacturing, support of innovation, STEM education, promotion of more inclusive and diverse research and research settings, along with additional efforts aimed at increasing research security. This COGR webinar provides members which an early look at the new Act, with a particular focus on the new research security provisions, agency authorizations and potential new STEM training and research opportunities.    

Presentation Slides

Recording (Log in required)


June 8, 2022

Comparison Chart: NIH Pre-Award and Post-Award Disclosures Relating to the Biographical Sketch and Other Support - read more...

This document compares the June 2022 version of the NIH Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Other Support with the prior version of the chart related by NIH.


May 3, 2022

NIH Data Management and Sharing Resource Page -


February 28, 2022

COGR Submits Letter to NIH on Genomic Data Sharing Policy RFI (NOT-OD-22-029) - read more...


February 15, 2022

COGR Submits Comment Letter to OSTP Concerning January 2022 Guidance for Implementing NSPM-33 - read more...

This letter contains COGR’s comments regarding the Implementation Guidance for National Security Presidential Memorandum 33, and stresses the need for transparency, a risk-based approach, and cross-agency consistency. 


January 13, 2022

NSPM Presentation Slides -

These are slides from COGR's webinar providing an overview of OSTP's NSPM-33 Implementation Guidance. 


January 10, 2022

Summary of NSTC Guidance for Implementing National Security Presidential Memorandum 33: Provisions Regarding DPIs, Consequences, Information Sharing and Research Security Programs - read more...

This summary highlights key points of the NSPM-33 Guidance that address the other topics covered by the document: DPIs, consequences, information sharing, and research security programs.


January 7, 2022

COGR Releases a Summary of NSTC Guidance for Implementing NSPM-33's Disclosure Requirements & Other Provisions - read more...

This summary highlights key points of the NSPM-33 Guidance’s disclosure requirements, including comparison of those provisions with current NIH and NSF requirements in this area. 


December 8, 2021

COGR Submits Comment Letter to NSF in Response to "Notice of a New System of Records: (SORN) - read more...

This letter provides comments regarding to NSF concerning its Privacy Act notice of a new system of records that describes the use of a data analytics tool to analyze information collected from researcher disclosures. 

Posted December 8, 2021


August 18, 2021

Federal Focus on Inappropriate Foreign Influence on Research: Practical Considerations in Developing an Institutional Response - read more...

This paper provides an overview of points that institutions should consider on issues related to research security as they perform risk assessments and develop/implement processes to appropriately address areas of higher research security risk


June 7, 2021

Materials Transfer in Academia: 20 Questions and Answers - read more...


December 18, 2020

COGR’s Survey on Institutional Disclosure Practices: Responding to Inappropriate Foreign Influence Amid Evolving Requirements

COGR’s Survey on Institutional Disclosure Practices: Responding to Inappropriate Foreign Influence Amid Evolving Requirements (Log in required)

Released December 2020

This paper provides analysis of the data collected via COGR's survey on institutional disclosure requirements regarding research support and researcher affiiliations.  It is availble only to COGR members. 


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]


August 23, 2019

ARCHIVED: Foreign Influence Resources Provided by COGR Members (ARCHIVED) - read more...

Posted October 3, 2019


August 16, 2019

Joint Association Letter to NASA on Sexual Harassment Federal Register Notice - read more...

Posted 8/16/19


July 12, 2019

Association Response to DoEd on Section 117 Reporting - read more...

Posted 7/12/19

This letter expresses joint association concerns regarding the continuing need for clarification regarding reporting requirements under Sec. 117 of the Higher Education Act of 1965. 


January 15, 2019

COGR Sends Letter to OMB on Data Standards - read more...

Posted January 15, 2019


November 6, 2017

COGR Submits Joint Association Letter to EPA Regarding Advisory Boards & Committees - read more...

Posted November 6, 2017


February 27, 2017

Actions for Reducing Administrative Work for Federally Sponsored Research

Reports from the National Academies, National Science Board, Federal Demonstration Partnership and others have highlighted increasing regulatory burden for federally funded research. Many of the recommendations for reducing burden target federal regulations and policies. Part 1 of the National Academies report, Optimizing the Nation’s Investment in Academic Research, also recommended that research institutions review policies developed to comply with federal regulations to determine whether the institution has created additional and unnecessary administrative burden.

The checklist COGR has created highlights actions that more closely adhere to regulation and policy or otherwise offer the potential to reduce administrative work in a number of areas including those researchers have identified as being particularly burdensome. Many of the approximately 100 actions put forward have previously been initiated at some of our member institutions with positive effect. However, we note that they may not be relevant, or applicable, to all institutions and that institutions may have reasons for establishing criteria that exceed the minimum regulatory requirements (e.g., state law). The list is intended to represent action taken, and ideas to consider, rather than a recommended action plan. We will continue to modify and expand the checklist in response to member feedback.

Administrative Burden Checklist


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


January 1, 2011

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

Click here to view the Recommendations.


January 1, 1998

Sponsored Programs Offices: A Continuing Evolution Responding to Federal Requirements

Click here to view