Comment Letter
COGR Submits Comments to OHRP in Response to HHS-OASH-2022-0011 "Use of a Single IRB for Cooperative Research" Draft Guidance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centers, submitted detailed feedback to the Office for Human Research Protections (OHRP) regarding the July 2022 draft guidance on the use of a Single Institutional Review Board (sIRB) for cooperative research.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
COGR Submits Response to NIH on Suggestions on the Draft NIH Chief Officer for Scientific Workforce Diversity Strategic Plan for FY 2022-2026 (NOT-OD-22-061) RFI
The Council on Governmental Relations (COGR), representing nearly 200 U.S. research universities and related institutions, provided formal feedback in response to the NIH’s Request for Information on its Draft Strategic Plan for Scientific Workforce Diversity for 2022-2026. COGR commended NIH’s efforts toward diversity, equity, inclusion, and accessibility (DEIA) and acknowledged alignment between
COGR Submits Comment Letter to NIH on NOT-OD-22-064
The Council on Governmental Relations (COGR), which represents nearly 200 major U.S. research universities and related institutions, submitted formal comments in response to the National Institutes of Health (NIH) Notice NOT-OD-22-064, seeking input on supplemental guidance for data management and sharing, especially regarding research involving American Indian and Alaskan Native (AI/AN) communiti
COGR Submits Letter to NIH on Genomic Data Sharing Policy RFI (NOT-OD-22-029)
The Council on Governmental Relations (COGR), representing 200 U.S. research universities and affiliated institutions, submitted comments to the National Institutes of Health (NIH) on proposed updates and long-term considerations for the NIH Genomic Data Sharing (GDS) Policy. COGR commends NIH’s efforts to solicit public input on balancing the imperative of data sharing—essential for scientific pr
COGR Submits Comment Letter to OSTP Concerning January 2022 Guidance for Implementing NSPM-33
This letter contains COGR’s comments regarding the Implementation Guidance for National Security Presidential Memorandum 33, and stresses the need for transparency, a risk-based approach, and cross-agency consistency.
