Comment Letter
COGR Response to NSF RFI on CHIPS and Science Act, Section 10343
The Council on Governmental Relations (COGR) submitted a detailed response to the National Science Foundation’s (NSF) Request for Information concerning the incorporation of ethical, social, safety, and security considerations into the agency’s merit review process, as mandated by the CHIPS and Science Act, Section 10343. COGR emphasizes the importance of clear and consistent definitions of risk c
COGR Responds to USDOJ’s Notice of Proposed Rulemaking—Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons
COGR, representing over 220 U.S. research institutions, submitted comments on the Department of Justice’s proposed rule aimed at restricting access to U.S. sensitive personal and government-related data by countries of concern. COGR expresses concern that the rule’s lack of exemptions for non-federally funded, non-clinical research would severely hinder essential international public health and fo
COGR Submits Response to Interim Final Rule—“Implementation of Controls on Advanced Technologies Consistent with Controls Implemented by International Partners”
COGR submitted a formal response to the U.S. Department of Commerce Bureau of Industry and Security's interim final rule regarding the implementation of export controls on advanced technologies. COGR acknowledges the necessity of safeguarding sensitive technologies amid evolving global threats and supports efforts to align U.S. regulations with those of international partners, while also emphasizi
COGR Submits Response to Health and Human Services Adoption of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
The Council on Governmental Relations (COGR), representing over 220 U.S. research universities and institutes, submitted formal comments to the U.S. Department of Health and Human Services (HHS) regarding the department’s interim final rule implementing the updated Office of Management and Budget (OMB) Uniform Guidance. COGR acknowledged the complexity of HHS’s dual-phased implementation—initial a
COGR Joins a Multi-Association Request to DOE’s RTES for Full Engagement with the Research Community Prior to Implementation of Risk Matrices
In this letter dated August 19, 2024, multiple leading organizations representing American research institutions and scientists urge the U.S. Department of Energy (DOE), specifically its Office of Research, Technology and Economic Security (RTES), to actively collaborate with the broader research community before finalizing new risk matrices intended to manage research security in extramural resea
COGR Joins a Multi-Association Response to NIH's Draft Public Access Policy
The joint letter from the Association of Public and Land-grant Universities (APLU), Association of American Universities (AAU), Association of American Medical Colleges (AAMC), and the Council on Governmental Relations (COGR) responds to the NIH Draft Public Access Policy, expressing general support for the policy’s objective of maximizing public access to NIH-funded research. The organizations no
Financial Assistance Regulations-Conflict of Interest and Conflict of Commitment Policy Requirements
This document is a formal response jointly submitted by the Association of American Universities (AAU), the Association of Public & Land-Grant Universities (APLU), and the Council on Governmental Relations (COGR) to the U.S. Department of Energy (DOE) regarding its Notice of Proposed Rulemaking (NPRM) on Financial Assistance Regulations concerning Conflict of Interest (COI) and Conflict of Com
COGR Responds to Request for Comments: Biosketch and Current and Pending Support Disclosure Policy
COGR provided feedback on NASA's proposed Biosketch and Current and Pending Support Disclosure Policy, emphasizing the need for uniformity with National Science and Technology Council (NSTC) common forms to minimize administrative burden and enhance compliance. COGR urged NASA to avoid unnecessary deviations from federal standards, align definitions and reporting requirements (especially for senio
COGR Submits Comments to NIH on Intramural Research Program Policy: Promoting Equity Through Access Planning
COGR responds to the NIH’s draft policy requiring licensees of NIH technologies to submit access plans aimed at promoting patient access, expressing support for the aim of equity but cautioning that such requirements may unintentionally complicate technology commercialization and deter potential licensees due to increased risks and uncertainties. COGR recommends that NIH focus on adjusting its own
COGR Responds to NIH Proposed Collection of Post-Award Reporting Requirements
COGR submitted a formal response to the National Institutes of Health (NIH) regarding proposed post-award reporting requirements for Data Management and Sharing Plans within the Research Performance Progress Report (RPPR). COGR’s comments primarily focus on section C.5.c of the RPPR, offering targeted suggestions to enhance the clarity, utility, and efficiency of the data collection process. Speci
