Proposal & Award Terms & Conditions

May 16, 2024

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


April 24, 2024

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


February 16, 2024

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


February 15, 2024

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


December 4, 2023

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


September 26, 2023

Preparing for a Government Shutdown: A List of Institutional Considerations - read more...


September 12, 2023

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...


September 6, 2023

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


August 2, 2023

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


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 30, 2023

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


June 13, 2023

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...


May 11, 2023

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


March 31, 2023

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." 


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 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...


December 19, 2022

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


December 14, 2022

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


November 4, 2022

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

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


September 6, 2022

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


August 15, 2022

Roles and Responsibilities: Considerations for Institutions -


August 15, 2022

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


June 13, 2022

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


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 -


April 21, 2022

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


March 1, 2022

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


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 31, 2021

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.

Click Here


December 21, 2021

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


September 22, 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. 


July 12, 2021

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


June 7, 2021

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


April 5, 2021

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.


February 10, 2021

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


September 22, 2020

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

Posted 9/22/20


August 4, 2020

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

Posted November 19, 2019


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]


December 5, 2019

COGR Releases Commentary on Disclosing Other Support -

Posted December 5, 2019


August 16, 2019

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

Posted 8/16/19


July 29, 2019

COGR Submits Comments to NSF on PAPPG -

Posted 7/29/19


March 21, 2019

HERD Survey Questions from COGR -

Posted 3/21/19


January 15, 2019

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

Posted January 15, 2019


December 10, 2018

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

Posted December 10, 2018


July 11, 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


January 19, 2018

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

Posted January 19, 2018


November 6, 2017

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

Posted November 6, 2017


September 19, 2017

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

Posted 9/19/17


August 24, 2017

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


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.” 


April 5, 2017

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

Posted April 5, 2017


February 6, 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.


December 20, 2016

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

Click here to view


October 6, 2016


August 8, 2016

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

Click here to view


July 8, 2016

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

Posted July 8, 2016


April 17, 2016

Establishment of Multiple Principal Investigator Awards

Click here to view


April 8, 2016

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

Posted April 8, 2016


February 11, 2016

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

Posted February 11, 2016


November 9, 2015

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

Posted November 9, 2015


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.


February 20, 2015

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

Posted February 20, 2015


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


October 1, 2009

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

Click here to view


August 1, 2007

University-Industry Relations brochure

Click here to view


March 1, 2007

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.


November 28, 2006

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


June 1, 2005

Cost and Facility Issues in Conducting Stem Cell Research

Summary of June 2005 COGR Meeting Discussion


February 28, 2005

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

Click here to view


November 1, 2001

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

Click here to view


October 21, 1998

50th Anniversary COGR Publication -


January 1, 1998

Sponsored Programs Offices: A Continuing Evolution Responding to Federal Requirements

Click here to view


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