Comment Letter
COGR Responds to OPM Proposed Rule on Schedule F Changes
The Council on Governmental Relations (COGR), representing over 225 major U.S. research institutions, submitted comments in response to the Office of Personnel Management’s (OPM) proposed rule aimed at improving performance, accountability, and responsiveness in the civil service. COGR's remarks focus particularly on the aspects of the rule that would potentially reclassify certain federal re
COGR Submits Response to OMB RFI on Deregulation
COGR responded to an Office of Management and Budget Request for Information on regulatory reform, advocating for significant reduction and harmonization of federal research regulations to minimize administrative burden and enhance the efficiency and effectiveness of federally funded research. The letter notes widespread duplication, inconsistency, and outdated requirements across federal agencies
COGR Initiates Contact with Newly Appointed NIH Director Regarding the Partnership Between NIH and Research Institutions and Requests Clarifications on NIH Policies
COGR has written to Dr. Jay Bhattacharya, Director of the National Institutes of Health (NIH), seeking clarification on recent NIH policy changes that have caused confusion and uncertainty within the research community. COGR requests detailed guidance on issues such as research award terminations, appeals processes, funding disruptions, centralized peer review, no-cost extensions, program changes
COGR, ABSA, and ASM Request Clarification on DURC/PEPP Policy March 25, 2025
Representatives of the American Society for Microbiology, the Association for Biosafety and Biosecurity International, and COGR are requesting a meeting with NIH leadership to discuss the implementation of the U.S. Government Policy for Oversight of Dual Use Research of Concern and Pathogens with Enhanced Pandemic Potential. They express concerns over the lack of detailed guidance on compliance re
COGR Joins Community Letter to NIH Requesting a Meeting to Discuss the Future Implementation of U.S. Government Policy for Oversight of DURC and PEPP
The letter, dated March 24, 2025, is a formal communication addressed to Dr. Matthew Memoli, Acting Director of the National Institutes of Health (NIH), from the leadership of the American Society for Microbiology (ASM), the Association for Biosafety and Biosecurity International (ABSA), and the Council on Governmental Relations (COGR). The organizations collectively express concerns regarding the
COGR Partners in Multi-Association Response Regarding FAR Case 2017-016, “Federal Acquisition Regulation: Controlled Unclassified Information” (Proposed Rule)
The joint comments submitted by major higher education associations—including the American Council on Education (ACE), Association of American Universities (AAU), Association of Public and Land-grant Universities (APLU), COGR, and EDUCAUSE—critique and provide recommendations on the Federal Acquisition Regulation (FAR) Case 2017-016, which introduces regulations governing Controlled Unclassified I
COGR Submits Comments in Response to NSF NITRD NCO’s “RFI—Development of an Artificial Intelligence Action Plan”
The Council on Governmental Relations (COGR) submitted comments in response to the National Science Foundation’s Request for Information concerning the development of a national Artificial Intelligence (AI) Action Plan, as mandated by Executive Order 14179. Representing over 225 research universities and affiliated institutions, COGR emphasized the importance of empowering U.S. academic research o
COGR Submits Comments in Response to DOE Interim Final Rule (IFR), "Update and Relocation of the Department of Energy Technology Investment Agreement Regulations"
The Council on Governmental Relations (COGR), representing over 225 research universities and affiliated institutions, submitted comments regarding the U.S. Department of Energy’s (DOE) interim final rule updating regulations on Other Transaction (OT) agreements. COGR acknowledges DOE's efforts to expand the use of OT agreements but expresses significant concerns about the removal of provisio
COGR Partners in Multi-Association Comment Letter on NIH Plan to Increase Findability and Transparency of Research Results Through the Use of Metadata and Persistent Identifiers (PID)—NOT-OD-25-050
The Association of Public and Land-grant Universities (APLU), Association of Research Libraries (ARL), Association of American Universities (AAU), and COGR express strong support for the NIH's plan to enhance the findability and transparency of research through the use of standardized metadata and persistent identifiers (PIDs) such as ORCID, DOI, and ROR. While endorsing the plan's goals, they rec
COGR Responds to NSF RFC on Proposed Intellectual Property Options
COGR submitted a response to the National Science Foundation’s (NSF) request for comments regarding proposed new intellectual property (IP) frameworks for public-private partnerships, expressing concern that prescribed, inflexible IP terms could hinder successful technology transfer and commercialization of federally funded research. COGR argued that current practices, which allow for the negotiat