Comment Letter
COGR Submits Comments to the Small Business Administration in Response to Federal Register Notice
The Council on Governmental Relations (COGR), representing over 200 public and private research universities and affiliated institutions, submitted formal comments to the U.S. Small Business Administration (SBA) regarding a proposed rule to revise ownership, control, and subcontracting requirements for the 8(a) Business Development Program. COGR expresses support for the intent behind the proposed
COGR Letter for Request for Comment for Common Disclosure Forms
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted detailed comments to the National Science Foundation regarding proposed common disclosure forms for Biographical Sketch and Current and Pending (Other) Support. COGR generally supports harmonizing federal disclosure requirements but highlights several challenges wit
COGR and ARIO Joint Response to ORI RFI Research Misconduct Policies
The Council on Governmental Relations (COGR) and the Association of Research Integrity Officers (ARIO) jointly responded to the Office of Research Integrity’s (ORI) request for input on revising the 2005 Public Health Service (PHS) Policies on Research Misconduct. Representing leading U.S. research universities and research integrity professionals, COGR and ARIO emphasized the importance of regula
COGR and AAMC Submit Joint Comment Letter to NIH on Cannabis RFI (NOT-AT-22-026)
The letter jointly submitted by the Association of American Medical Colleges (AAMC) and the Council on Governmental Relations (COGR) responds to an NIH Request for Information concerning barriers to researching the health effects of cannabis and its constituents. The organizations emphasize their support for increased federal efforts to assess the therapeutic potential of cannabinoid and cannabis-
COGR Submits Comments to OHRP in Response to HHS-OASH-2022-0011 "Use of a Single IRB for Cooperative Research" Draft Guidance
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated medical centers, submitted detailed feedback to the Office for Human Research Protections (OHRP) regarding the July 2022 draft guidance on the use of a Single Institutional Review Board (sIRB) for cooperative research. COGR commends the OHRP for addressing the complexities of sIRB implemen
Multi-Association Follow Up Letter to DoEd on Section 117
The letter from the American Council on Education (ACE), addressed to senior officials at the U.S. Department of Education (ED), conveys appreciation for updates regarding the management and reporting requirements of Section 117 of the Higher Education Act, which pertains to the disclosure of foreign gifts and contracts by higher education institutions. ACE acknowledges the helpfulness of the June
COGR Submits Comments in Response to NIH Guide Notice NOT-OD-22-131 Regarding Protecting Privacy When Sharing Human Research Participant Data
The Council on Governmental Relations (COGR), representing nearly 200 leading research institutions, submitted a response to the NIH's Draft Supplemental Information for Data Management and Sharing (NOT-OD-22-131). The COGR commends the NIH for its flexible and principle-based approach to protecting research participant privacy when sharing data, emphasizing the importance of considering both
COGR Submits Comments to NSF on the Draft PAPPG (NSF 23-1)
The Council on Governmental Relations (COGR), representing 200 major U.S. research institutions, submitted formal comments to the National Science Foundation (NSF) on the draft Proposal and Award Policies and Procedures Guide (PAPPG, NSF 23-1). COGR commends NSF for its technological advancements, such as implementing Research.gov and retiring Fastlane.gov, but raises concerns about duplicative sy
COGR Submits Comments to USDA on Proposal Rule on Standards for Birds Not Bred for Use in Research Under AWA
The document is a formal comment letter submitted by the Council on Governmental Relations (COGR), an association representing nearly 200 U.S. research universities and related institutions, to the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (USDA APHIS) concerning a proposed rule on standards for birds not bred for use in research under the Animal Welfare Act (AWA)
COGR Submits Comments to NASA on T&C's Affecting Procurement
COGR submitted formal comments in response to NASA's proposed requirement for recipients of financial assistance awards to obtain quotations from small and/or minority businesses, women's business enterprises, or labor surplus area firms for acquisitions exceeding the simplified acquisition threshold. While COGR expresses strong support for President Biden’s Executive Order 13985 on advancing raci
