Comment Letter
COGR & AAU Submit Joint Comments in Response to Unlocking the Full Potential of Intellectual Property by Translating More Innovation to the Marketplace (Docket No. PTO-C-2024-004)
COGR and AAU, representing leading U.S. research universities, submitted comments to USPTO Director Kathi Vidal expressing agreement with AUTM’s positions and addressing key issues impacting university technology transfer and innovation commercialization. They voiced serious concerns about NIST's draft march-in rights framework, warning that its adoption could deter investment and harm patent lice
COGR Responds to Advance Notice of Proposed Rulemaking—“Provisions Regarding Access to Americans’ Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern”
The Council on Governmental Relations (COGR), which represents over 200 U.S. research universities and affiliated institutes, submitted comments in response to the U.S. Department of Justice’s Advance Notice of Proposed Rulemaking (ANPRM) concerning restrictions on access to Americans’ sensitive personal and government-related data by countries of concern. COGR acknowledges the importance of prote
COGR Joins AIRI in Submitting Comments to OMB on the Treatment of Salaries and the Executive Level II Salary Limitation
The Council on Governmental Relations (COGR) and the Association of Independent Research Institutes (AIRI), collectively representing over 300 research institutions, formally express concerns regarding a potential policy change that would extend the Executive Level II federal salary limitation to indirect salaries funded by institutions themselves. The organizations argue that, for the past 30 yea
COGR Submits Response to CDC on Notice of Proposed Rulemaking on Possession, Use, and Transfer of Select Agents and Toxins; Biennial Review of the List of Select Agents and Toxins
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted feedback to the Centers for Disease Control and Prevention (CDC) regarding the Notice of Proposed Rulemaking on the Possession, Use, and Transfer of Select Agents and Toxins, and its biennial review of the select agents list. COGR supports the proposed removal of Br
COGR Responds to APHIS Notice of Proposed Rulemaking on Agricultural Bioterrorism Protection Act of 2002; Biennial Review and Republication of the Select Agent and Toxin List
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted comments in response to the USDA’s Animal and Plant Health Inspection Service (APHIS) Notice of Proposed Rulemaking (NPRM) regarding the biennial review and republication of the Select Agent and Toxin List under the Agricultural Bioterrorism Protection Act of 2002.
COGR Joins a Multi-Association Response to the Request for Comments to Docket Number DoD–2023–OS–0063 / Regulatory Identifier Number (RIN) 0790–AL49, “Cybersecurity Maturity Model Certification (CMMC) Program”
The collective comments submitted by the American Council on Education (ACE), Association of American Universities (AAU), Association of Public and Land-Grant Universities (APLU), COGR, and EDUCAUSE address the Department of Defense’s proposed updates to the Cybersecurity Maturity Model Certification (CMMC) Program. The associations commend the DoD for recognizing that fundamental research general…
COGR Responds to EPA Scientific Integrity Policy Draft for Public Comment (EPA-HQ-ORD-2023-0240; FRL-10973-01-ORD)
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted formal comments to the Environmental Protection Agency (EPA) regarding the agency's draft Scientific Integrity Policy. While COGR strongly supports the policy's overall goal of enhancing scientific integrity and promoting transparent, objective research, t
COGR, EDUCAUSE, and AAU Submit Joint Comment Letter to GSA on Cyber Threat and Incident Reporting & Information Sharing (FAR 2021-017)
EDUCAUSE, COGR, and the Association of American Universities (AAU) submitted comments expressing concern over the scope and impact of the proposed changes in Federal Acquisition Regulation Case 2021-017, which would require all federal contractors—including higher education institutions engaged in fundamental research—to comply with broad cyber incident reporting and software bill of materials (SB
Higher Education Associations Comments to NIST
A coalition of leading academic associations, including AAU, APLU, AAMC, ACE, AUTM, and COGR, submitted comments opposing the National Institute of Standards and Technology's (NIST) Draft Interagency Guidance Framework for Considering the Exercise of March-In Rights under the Bayh-Dole Act. They argue that the proposed framework introduces unnecessary ambiguity, focuses inappropriately on “reasona
COGR Submits Comments to NIST on Draft Interagency Guidance Framework for Considering the Exercise of March In Rights
COGR, representing over 200 U.S. research institutions, submitted comments urging the withdrawal of the proposed Interagency Guidance Framework for Considering the Exercise of March-In Rights under the Bayh-Dole Act. COGR argues that the Framework, particularly its consideration of product pricing as a trigger for march-in, would undermine successful technology transfer practices, deter industry p
