Comment Letter
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, AAU, and APLU Letter to DOE on Financial Assistance Regulations-Conflict of Interest and Conflict of Commitment Policy Requirements
The Association of American Universities (AAU), Association of Public & Land-Grant Universities (APLU), and COGR submitted comments to the Department of Energy (DOE) regarding its proposed rule on Financial Assistance Regulations related to Conflict of Interest (COI) and Conflict of Commitment (COC) policies. They argue that the proposed requirement for institutions to develop stand-alone COC
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
COGR and AAMC Submit Joint Letter to DEA on Rescheduling Marijuana
The Association of American Medical Colleges (AAMC) and the Council on Governmental Relations (COGR) submitted joint comments to the DEA in support of the proposed rescheduling of marijuana from Schedule I to Schedule III under the Controlled Substances Act, highlighting that this shift would reduce barriers and administrative burdens for cannabis research at their member institutions. They recomm
COGR Responds to OMB's Invitation to Provide Comments and Technical Corrections to Address Select Items in the Recently Released OMB Guidance for Federal Financial Assistance (Fourth Look)
This comment letter offers detailed comments and proposed technical corrections to the OMB’s updated Uniform Grant Guidance for Federal Financial Assistance, set to take effect October 1, 2024. The letter highlights COGR's recommendations on timely implementation of new thresholds for equipment and subawards, urges reconsideration of changes regarding fixed amount awards, and advocates for the rea
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
