Comment Letter
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
COGR Joins AAU and APLU Presidents in Submitting Joint Letter to Government Officials in Response to Unnecessary Disruptions to Federally Supported Research
The letter from the leaders of the AAU, APLU, and COGR expresses deep concern about recent disruptions to federally funded research resulting from executive actions and agency procedures, including interrupted payments, unclear directives relating to DEI compliance, abrupt project terminations, and a new NIH cap on facilities and administrative cost reimbursement. The authors urge federal official
COGR Joins in Community Letter to USDA on Research Access to Germplasm
The letter, addressed to Director Manjit Misra of the National Institute of Food and Agriculture at the USDA, expresses concerns from leading academic and research organizations regarding the USDA's October 8, 2024 announcement on research access to germplasm developed with federal funds. The organizations interpret the announcement as potentially signaling a move toward mandating unrestricte
COGR Submits Response to NSF's Comment Request: NSF PAPPG (NSF 26-1)
The Council on Governmental Relations (COGR), representing over 220 U.S. research institutions, submitted detailed comments to the National Science Foundation (NSF) regarding proposed revisions to the NSF Proposal and Award Policies and Procedures Guide (PAPPG 26-1). COGR commends NSF's history of collaborative policy development but expresses concern over certain ambiguities, new compliance
Letter to President Trump - Incoming Administration
COGR congratulates President Trump on his inauguration and urges his administration to address the growing administrative burden caused by overlapping and inconsistent federal research regulations. The letter highlights that the proliferation of federal requirements—particularly over the past decade—has imposed significant costs and diminished faculty research productivity, potentially jeopardizin
Letter to Incoming Trump Administration Officials
COGR, representing over 230 U.S. research institutions, addresses a letter to federal officials urging action to reduce administrative burdens hindering federally funded research. The organization recommends creating a centralized Research Policy Board and a dedicated leadership position to streamline and harmonize research regulations, advocating for unified regulatory frameworks across agencies,
COGR Submits Comments to Department of Commerce on Ethical Guidelines for Research Using Pervasive Data
COGR, representing over 220 U.S. research institutions, submitted comments to the National Telecommunications and Information Administration (NTIA) regarding the development of ethical guidelines for research using pervasive data. COGR underscores the complexity of the existing regulatory landscape and cautions against NTIA introducing additional guidelines, recommending instead that the Departmen
