Archived
COGR and AAU Submit Joint Letter to DOD on DFARS Case 2013-D-018
The letter, jointly submitted by the Council on Governmental Relations (COGR) and the Association of American Universities (AAU), addresses the Department of Defense’s (DoD) proposed updates to the Defense Federal Acquisition Regulation Supplement (DFARS) (Case 2013-D-018), specifically regarding new requirements for safeguarding covered defense information in contracts. While COGR and AAU acknowl
COGR Submits Letter to OMB Requesting “Implementation of Sensible Procurement Standards”
The Council on Governmental Relations (COGR), in concert with multiple higher education and nonprofit research organizations, submitted this formal letter to the Office of Management and Budget (OMB) to address concerns and propose revisions regarding the implementation of procurement standards under 2 CFR 200.317-326 for recipients of federal grants and cooperative agreements. While expressing ap
Analysis of Common Rule Comments
In January 2016, COGR staff and university and association volunteers began an analysis of the 2,186 comments submitted to regulations.gov in response to the Notice of Proposed Rulemaking (NPRM) on the Federal Policy for the Protection of Human Subjects (Common Rule).
COGR Submits Comments on Common Rule NPRM and Provides Summary Brief
COGR Detailed and Summary Comments on Common Rule
COGR Submits Comments on NIH Guidelines on Recombinant or Synthetic Nucleic Acid Molecules
COGR responded to the National Institutes of Health’s (NIH) request for public comments regarding proposed amendments to the NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. COGR expresses support for the NIH’s intention to optimize the benefit of the Recombinant DNA Advisory Committee (RAC) review process by restricting detailed gene transfer reviews to excep
October 30, 2015- COGR/AAU Joint Letter on DFARS Case 2013-D018
The joint letter from the Council on Governmental Relations (COGR) and the Association of American Universities (AAU) addresses concerns regarding the interim DFARS rule (Case 2013-D018), which introduces new safeguarding and reporting requirements for institutions handling controlled defense information. COGR and AAU, representing leading research universities, highlight significant compliance bu
September 24, 2015 COGR Letter to OMB on UG Deviations
The Council on Governmental Relations (COGR), representing research universities, addressed a formal letter on September 24, 2015, to the Office of Management and Budget (OMB) expressing concerns about federal agencies’ deviations from the Uniform Guidance (UG) under 2 CFR 200, which governs administrative requirements, cost principles, and audit requirements for federal awards. COGR highlighted r
September 4, 2015 - COGR Comment Letter to the Department of Labor Wage and Hour Division Regarding RIN 1235-AA11
The September 4, 2015 letter from the Council on Governmental Relations (COGR), representing 190 research universities and affiliated institutes, addresses the U.S. Department of Labor's proposed changes to the exemptions for executive, administrative, professional, outside sales, and computer employees under RIN 1235-AA11. The primary concern expressed is the Department’s plan to significant
June 30, 2015 - Revisions to Procurement Standards and Grace Period Extension
The document, authored by the Council on Governmental Relations (COGR) and addressed to the Office of Federal Financial Management within the White House Office of Management and Budget (OMB), presents a formal request for revisions to the federal procurement standards under the Uniform Guidance (2 CFR Part 200) and an extension to the grace period for their implementation. COGR, representing rese
April 24, 2015 - Comment Letter to the FAA on Proposed Rule for the Operation and Certification of Unmanned Aircraft Systems
COGR signed on to a comment letter to the FAA on its proposed rule for the Operation and Certiification of Small Unmanned Aircraft System.
