Comment Letter
Association Responses to Petitions to the USDA
The joint letter from the Association of American Universities (AAU) and the Council on Governmental Relations (COGR) responds to a USDA request for public comment on a petition proposing amendments to the Animal Welfare Act (AWA) regulations. Specifically, the petition asks for the development of specific, ethologically appropriate standards for nonhuman primates used in research. In their respon
COGR Submits Comments to NIH on Postdocs Supported by NRSA and RGA Awards
The document is a formal correspondence from the Council on Governmental Relations (COGR) to Drs. Kay Lund and Henry Khachaturian at the National Institutes of Health (NIH), following a recent meeting regarding postdoctoral research funding and compliance. The letter, sent by Jackie Bendall, outlines the key concerns and requests for clarification raised by COGR and research compliance committees
COGR & AIRI Submit Joint Letter on Procurement as Requested by OMB
The Council on Governmental Relations (COGR), representing over 190 major research universities and institutions, and the Association of Independent Research Institutes (AIRI), submitted a detailed analysis to the Office of Management and Budget (OMB) regarding the administrative and cost implications of enforcing a $3,500 micro-purchase threshold for federally funded procurements. Based on survey
COGR and AAU Submit Joint Comments on OMB's Draft Open Source Policy
The letter, jointly authored by the Council on Governmental Relations (COGR) and the Association of American Universities (AAU), provides a detailed response to the Office of Management and Budget’s (OMB) Draft Open Source Policy. Both COGR and AAU support the principle of providing public access to and preservation of federally funded research outcomes, recognizing the significant national benefi
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
