Proposal & Award Terms & Conditions

Framework for Navigating the 2025 Administration Transition - read more...

Points to Consider for Reimbursement of Expenses Under Active Grants Federal Actions and Notices V.2 - read more...

COGR Joins AAMC-Led Amicus Brief Opposing Federal Stay in NIH Grant Restoration Cases - read more...

COGR Advocates for Full Reinstatement of NIH Grants in Joint Association Letter to Director, Dr. Bhattacharya - read more...

Fact Sheet: Defend the Spend - read more...

Fact Sheet #1: Defend the Spend - read more...

Navigating the Storm: Institutional Perspectives on a Changing Federal Landscape: June 2025 COGR Meeting - read more...

Legal Headwinds: Navigating Litigation, Policy Shifts, and Federal Pressure on Higher Education: June 2025 COGR Meeting - read more...

COGR Responds to OPM Proposed Rule on Schedule F Changes - read more...

Updated: Framework for Navigating the 2025 Administration Transition - read more...

COGR Submits Response to OMB RFI on Deregulation - read more...

Statement by COGR President Matt Owens on the NIH’s Announcement to Move up the Implementation of the NIH Public Access Policy - read more...

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COGR Joins Amicus Brief on HHS/NIH Grant Terminations Suit - read more...

COGR. APLU, and AAU Submit Joint Comments on DFARS Case 2020-D028 [Docket DARS-2024-0027] - read more...

COGR Submits Response to Health and Human Services Adoption of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards - read more...

Implementation and Readiness Guide for the OMB Guidance for Federal Financial Assistance - read more...

Slides: Going AI: Cutting-Edge Strategies for Enhancing Research Administration Efficiency through Practical Application of Artificial Intelligence - read more...

COGR Responds to Request for Comments: Biosketch and Current and Pending Support Disclosure Policy - read more...

Overview of OSTP Guidelines for Research Security Programs at Covered Institutions - read more...

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...

Great Minds: Brainstorming & Benchmarking with COGR Member Institutions: June 2024 - read more...

NIH Latest Updates - read more...

OMB Advance Questions: June 2024 Meeting - read more...

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

COGR's First Look at OMB's Guidance on Federal Financial Assistance - read more...

Update Now Available (V.4): COGR Matrix of Science & Security Laws, Regulations, and Policies - read more...

COGR Letter to OEI HHS-OIG - read more...

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...

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

COGR, APLU, and AAU Submit Joint Response to Request for Public Comment on Common Disclosure Forms for the Biographical Sketch and Current and Pending (Other) Support for Use in Submission of Research Applications - read more...

Times Up for TikTok Webinar Materials (Slides & Recording) - read more...

At the beginning of this year, the government issued OMB Memorandum M–23–13 banning TikTok on Government Devices.  More recently, DOD, GSA, and NASA issued an interim rule amending the FAR to prohibit ByteDance Covered Application on any information technology owned or managed by the Government or on any information technology used or provided by the contractor under a contract as FAR 52.204-27.  Citing the prohibition on having or using a covered application on information technology, including certain equipment used by Federal contractors, is a national security measure to protect Government information and information and communication technology systems. This webinar provides essential information about the implications of the various federal and state requirements banning Tik Tok and ByteDance Apps for research administrators.  

Speakers for this webinar include William Ferreira, Partner, Hogan Lovells; Mary Ann Blair, Associate Vice President, Chief Information Security Officer, Carnegie Mellon University; Jennifer Rodis, Policy & Planning Analyst, Research and Sponsored Programs, University of Wisconsin-Madison; and Vivian Holmes, Executive Director, Research Administration Services, Massachusetts Institute of Technology. Hosted on September 6, 2023, at 2 p.m. [ET]. 

Questions on this topic may be sent to Krystal Toups at ktoups@cogr.edu.

COGR Analysis on Executive Order 14104 “Federal Research and Development in Support of Domestic Manufacturing and U.S. Jobs” - read more...

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...

COGR Submits Comment Letter in Response to Notice to Announce NIH Updated Policy Guidance for Subaward/Consortium Written Agreements (88 FR 36603) - read more...

COGR Responds to the National Science Foundation Proposal/Award; Information— NSF Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 24-1) Comment Request - read more...

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

COGR Publishes "Analyzing Personal Financial and Institutional Conflicts of Interest in Academic Research Contexts" - read more...

COGR has published a new report:  “Analyzing Personal Financial and Institutional Conflicts of Interest in Academic Research Contexts.”  Ensuring the objective conduct of research, free from bias, is one of a research institution’s most important duties, as well as a key focus for federal research funding agencies.  This report discusses both personal financial and institutional conflict of interest issues in the context of situations in which these conflicts most commonly occur, including consulting, licensing, and clinical studies.  The report also addresses federal research funding agencies’ recent focus on the intersection of conflicts and malign foreign influence, and includes key regulations and guidance documents, points institutions should consider in evaluating scenarios, and case studies that can be used to foster discussion and support educational efforts. 

“Analyzing Personal Financial and Institutional Conflicts of Interest in Academic Research Contexts” complements COGR’s 2021 publication:  "Principles for Conflict of Commitment Concerns in Academic Research." 

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 ktoups@cogr.edu or David Kennedy at dkennedy@cogr.edu if you have comments or questions

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

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

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.

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

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

NIH Data Management and Sharing (DMS) Policy Readiness Webinar on January 17 - read more...

The final countdown approaches for the January 25, 2023, implementation of the NIH Data Management and Sharing (DMS) Policy. On January 17, COGR hosted Michelle Bulls, Director, Office of Policy for Extramural Research Administration (OPERA), NIH, to discuss the new policy as the community prepares. This webinar covered updates from NIH, presented budgeting issues recently released in Chapter 4 Part I of the COGR NIH DMS Readiness Guide, and other topics of interest. 

PowerPoint Presentation

Webinar Recording (log in required)

For additional information and resources on the NIH Data Management and Sharing Policy, please visit COGR’s Resource Page and the COGR NIH DMS Readiness Guide, including the recently released Chapter 4 Part I:  COGR Review of the Final NIH Policy for Data Management and Sharing:  Budgeting and Costing. 

COGR's Review of the Final Policy on Data Management and Sharing: Budgeting and Costing (Readiness Guide Chapter 4 Part I) - read more...

COGR Submits Letter to Dr. Tabak on the NIH Modular Grant Application and Award Process - read more...

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.

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

Joint Comments from AAU, AAMC, APLU, ACE and COGR to NSF on Standard Disclosures - read more...

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

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. 

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

Digging Into DPIs (Digital Persistent Identifiers) 9/23 Webinar Materials - read more...

EO 14042 Ensuring Adequate COVID Safety Protocols for Federal Contractors & OSHA Emergency Temporary Standard: Guidance and Considerations Resources - read more...

Roles and Responsibilities: Considerations for Institutions - read more...

COGR Releases NIH Data Management Implementation Roles & Responsibilities: Considerations for Institutions - read more...

ARCHIVED: COGR COVID Resources & Publications - read more...

COGR Submits Comments to NSF on the Draft PAPPG (NSF 23-1) - read more...

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.

NIH Data Management and Sharing Resource Page - read more...

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

Lawrence Tabak (Guest Speaker Presentation): March 2022 COGR Meeting - read more...

NSPM Presentation Slides - read more...

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

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.

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. 

Framework for Review of Individual Global Engagements in Academic Research - read more...

This paper provides research institutions with an underlying structure to support the analysis of international engagements by their researchers, assess potential risks, and develop strategies for mitigation.

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COGR Submits Letter to OSTP on Reducing Administrative Burden - read more...

This letter provides specific suggestions to OSTP for achieving its objective of reducing administrative burden associated with federally funded research, including suggestions regarding research security requirements.  

Posted December 21, 2021

Principles for Evaluating Conflict of Commitment Concerns in Academic Research (Update) - read more...

Updated September 22, 2021

This paper examines the issue of conflict of commitment in the context of concerns regarding inappropriate foreign influence, promoting transparency, and avoiding conflicts. 

COGR, AAU, and APLU Submit Letter to DOE on Order 142.3B - read more...

Posted July 12, 2021

This letter sets forth comments to the Dept. of Energy from COGR, Association of American Universities (AAU), and Association of Public and Land-grant Universities (APLU) regarding the application of DOE Order 142.3B and the removal of the  limited screening exemption for U.S. universities

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

Joint Association Comments on NIST NPRM Proposed Changes to Part 401 and 404 - read more...

Posted April 5, 2021

This letter provides association comments regarding changes proposed to Part 401 Rights to Inventions Made by Nonprofit Organizations and Small Business Firms Under Government Grants Contracts and Cooperative Agreements.

COGR Comment Letter to NSF on 22-1 PAPPG - read more...

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. 

COGR Releases Current and Pending Support Table (NSF) - read more...

Posted 9/22/20

Conflict of Commitment Policies for COGR Member Institutions - read more...

Posted November 19, 2019

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

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]

COGR Releases Commentary on Disclosing Other Support - read more...

Posted December 5, 2019

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

Posted 8/16/19

COGR Submits Comments to NSF on PAPPG - read more...

Posted 7/29/19

HERD Survey Questions from COGR - read more...

Posted 3/21/19

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

Posted January 15, 2019

Joint Association Letter to OSP-NIH: RFI on Proposed Provisions for a Draft Data Management and Sharing Policy - read more...

Posted December 10, 2018

Joint Association Letter to EPA on Proposed Rule to Limit Scientific Research - read more...

COGR, along with the AAMC, AAU and APLU submit their joint letter to the Environmental Protection Agency (EPA) opposing a proposed rule that seeks to limit the scientific research it will consider unless all underlying data are made publicly available. The mechanisms of competitive grant funding and peer review of publications serve to ensure the validity of science and integrity of research even when the data are not available to the public for legitimate, reasonable and ethical reasons. Restrictions related to data availability, such as the privacy of individual health information should not discount the validity of the research, or its findings, and should not prevent the EPA from using credible research in its rulemaking decisions.

If instituted, the proposal will prevent the EPA from evaluating the best available evidence when making its regulatory decisions. Because of this, the cosigning organizations urged the withdrawal of the proposed rule and invite the EPA to engage with the scientific community to discuss how evidence-based policy should be developed to protect human health and the environment.

Posted July 11, 2018

COGR Sends Follow Up Letter to Open Science Committee Members on Public Access - read more...

Posted January 19, 2018

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

Posted November 6, 2017

Joint Comment Letter to DoEd on Open Licensing - read more...

Posted 9/19/17

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

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.” 

COGR Submits Letter to DOD Regarding Pre/Post Award Administrative Matters on Financial Assistance Awards - read more...

Posted April 5, 2017

COGR’s Response to DOD on NPRMS Implementing 2 CFR Part 200 - read more...

COGR’s response to a series of six (6) DoD NPRMs updating the DoD Grant and Agreement Regulations (DoDGARs) to implement 2 CFR part 200.

COGR Submits Letter to DOD on Proposal Submission Deadlines - read more...

Click here to view

GAO Report on Federal Research Grants

COGR Preliminary Analysis of GAO Report on Federal Research Grants 

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

Click here to view
 

COGR Submits Letter to OMB on COI Under Uniform Guidance - read more...

Posted July 8, 2016

Establishment of Multiple Principal Investigator Awards

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COGR Comments on DOI Conflict of Interest Policy - read more...

Posted April 8, 2016

COGR Seeks Clarification from the U.S. Fish & Wildlife Service on COI Language - read more...

Posted February 11, 2016

COGR Submits Letter to DOD on COI Requirements - read more...

Posted November 9, 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

COGR Guide to 2 CFR 200.430 Compensation-Personal Services

Click here for the Guide.

February 20, 2015 - COGR Letter to EPA on Interim Conflict of Interest Policy - read more...

Posted February 20, 2015

COGR Readiness Document - Uniform Guidance -

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

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

COGR Response to Grants Reform

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

COGR Proposal to the A-21 Task Force

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

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.

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

Click here to view the Recommendations.

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

Rights In and Responsibilities for Technical Data and Computer Software Under Federal Awards

Click here to view

University-Industry Relations brochure

Click here to view

COGR's Contracts and Intellectual Property Committee has finished its web-based paper on the CREATE (Cooperative Research and Technology Enhancement) Act, entitled "...A Guide for Academic Research Institutions."

Click here to view the paper.
Click here to view slide presentation at AUTM conference, March 2007.

COGR comments to NIH on the proposed policy for sharing of data obtained in NIH supported or conducted Genome-Wide Association studies

Click here to view the letter

Cost and Facility Issues in Conducting Stem Cell Research

Summary of June 2005 COGR Meeting Discussion

Cost of Doing Business Study

Click here to view Study.
Click here to view Table of Contents.
Click here to view Inventory.

COGR Letter to OMB on Research Terms and Conditions for Grants under Federal Research and Research Related Programs

Click here to view

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

Click here to view

50th Anniversary COGR Publication - read more...

Sponsored Programs Offices: A Continuing Evolution Responding to Federal Requirements

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Notification Letter for 45 CFR 46.118 Determinations for NSF Awards

COGR has been working with NSF staff to develop a letter that universities can submit for proposals lacking definite plans for involvement of human subjects. The letter indicates that the grant or protocol meets the requirements of 45 CFR 46.118 and stipulates that “one year from the date identified above, the Authorized Organizational Representative is required to either verify that the project continues to lack immediate plans for the involvement of human subjects, their data, or their specimens; or provide documentation to the cognizant NSF Program Officer to demonstrate that IRB approval has been obtained.” Universities that utilize this notification letter will therefore track the expiration through their financial or IRB systems (or other mechanisms). These changes will be reflected in the next version of the NSF Proposal and Award Policies and Procedures Guide that is scheduled for release in October 2016 and a link provided to the letter which will be available on the NSF website. 

Troublesome Clauses

COGR and MIT jointly are maintaining a list of government contract clauses reported to us by universities that contain restrictions on publications and participation of foreign nationals.
Click here to view the list