Comment Letter
COGR Posts DRAFT Response to OMB (Uniform Guidance)
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutes, submitted a detailed response to the Office of Management and Budget’s (OMB) Request for Information regarding proposed updates to federal grant regulations (notably, 2 CFR Parts 25, 170, 175, 176, 180, 182, 183, and 200). The letter outlines a series of recommendations aimed a
COGR's Joint Response to NASA’s “New Conflict of Interest and Conflict of Commitment Policy for Recipients of NASA Financial Assistance Awards”
The document is a formal response from leading organizations in the higher education and research university sector to NASA regarding its proposed new Conflict of Interest (COI) and Conflict of Commitment (COC) Policy for recipients of NASA financial assistance awards. The signatories commend NASA's initiative to enhance research integrity and address both financial and non-financial conflict
COGR Submits Comments in Response to ANPRM Entitled Wild and Exotic Animal Handling, Training of Personnel Involved with Public Handling of Wild and Exotic Animals, and Environmental Enrichment for Species
The Council on Governmental Relations (COGR), representing over 200 research universities and affiliated institutions, submitted comments in response to the USDA Animal and Plant Health Inspection Service's (APHIS) advance notice of proposed rulemaking concerning wild and exotic animal handling, personnel training, and, notably, environmental enrichment standards for species covered under the
COGR Signs on to Multi-Association Letter to DoEd Regarding Foreign Gift & Contract Disclosures (ED-2022-SCC-0159)
The letter, submitted by the American Council on Education and a coalition of higher education associations, provides detailed comments to the U.S. Department of Education regarding its proposed Information Collection Request (ICR) related to reporting foreign gifts and contracts under Section 117 of the Higher Education Act. The organizations affirm their commitment to transparency and compliance
COGR Submits Comments to GSA Regarding the Transition of the Federal Audit Clearinghouse
COGR provided comments to the GSA regarding the transition of the Federal Audit Clearinghouse from the U.S. Census Bureau to the GSA.
COGR Requests a 30-Day Extension to Respond to OMB's RFI
COGR requested a 30-day extension to respond to OMB’s RFI regarding updates to 2 CFR Part 200, Uniform Guidance.
COGR Responds to the Request for Information: Clinical Research Infrastructure and Emergency Clinical Trials
The Council on Governmental Relations (COGR), representing over 200 U.S. research institutions, submitted a detailed response to the White House Office of Science and Technology Policy's Request for Information on enhancing clinical research infrastructure for emergency clinical trials (ECR). Drawing on extensive experience from the COVID-19 pandemic, COGR emphasized the necessity for rapid,
COGR Responds to HHS Notice of Proposed Rulemaking “Confidentiality of Substance Abuse Disorder Patient Records”
COGR, representing over 200 U.S. research institutions, submitted comments on the Department of Health and Human Services' proposed rule to align the confidentiality regulations for substance abuse disorder patient records (42 CFR Part 2) with HIPAA. COGR supports the alignment to reduce dual compliance burdens and enhance research capabilities, advocating for clearer allowances for creating de-id
COGR Submits Letter to HHS on Timely Establishment of Indirect Cost and Fringe Benefit Rate Agreements
COGR submitted a letter to Mak Karim, the National Director for Cost Allocation Services at the U.S. Department of Health and Human Services. In the letter, COGR requests assistance to facilitate improvements in the speed of the review and approval process associated with indirect cost and fringe benefit rates.
COGR Submits Letter to Dr. Tabak on the NIH Modular Grant Application and Award Process
The letter, sent by the Council on Governmental Relations (COGR) to Dr. Lawrence A. Tabak, Acting Director of the National Institutes of Health (NIH), highlights concerns with the current limitations of the NIH Modular Grant Application and Award process. COGR acknowledges the positive impact and original intent of the modular grant system, introduced in 1998 to reduce administrative burden and fo
