Comment Letter
COGR Submits Letter to OMB Requesting “Implementation of Sensible Procurement Standards”
The Council on Governmental Relations (COGR), in concert with multiple higher education and nonprofit research organizations, submitted this formal letter to the Office of Management and Budget (OMB) to address concerns and propose revisions regarding the implementation of procurement standards under 2 CFR 200.317-326 for recipients of federal grants and cooperative agreements. While expressing ap
Analysis of Common Rule Comments
In January 2016, COGR staff and university and association volunteers began an analysis of the 2,186 comments submitted to regulations.gov in response to the Notice of Proposed Rulemaking (NPRM) on the Federal Policy for the Protection of Human Subjects (Common Rule).
Joint COGR/AAU/APLU/AUTM Letter Submitted to DOEd on Open License Requirement
The document is a formal letter submitted on December 14, 2015, by the Association of American Universities (AAU), the Association of Public Land-grant Universities (APLU), the Association of University Technology Managers (AUTM), and the Council on Governmental Relations (COGR), collectively representing major research universities and technology transfer professionals in the U.S. The letter addr
COGR Submits Comment Letter to NSF on Research Terms and Conditions
The letter from the Council on Governmental Relations (COGR), addressed to the National Science Foundation in December 2015, offers a detailed response to revised Research Terms and Conditions (RTCs) that implement the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200, or Uniform Guidance). COGR commends the collaborative efforts of federal
COGR Submits Comments on Common Rule NPRM and Provides Summary Brief
COGR Detailed and Summary Comments on Common Rule
COGR Submits Comments on NIH Guidelines on Recombinant or Synthetic Nucleic Acid Molecules
COGR responded to the National Institutes of Health’s (NIH) request for public comments regarding proposed amendments to the NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules. COGR expresses support for the NIH’s intention to optimize the benefit of the Recombinant DNA Advisory Committee (RAC) review process by restricting detailed gene transfer reviews to excep
October 30, 2015- COGR/AAU Joint Letter on DFARS Case 2013-D018
The joint letter from the Council on Governmental Relations (COGR) and the Association of American Universities (AAU) addresses concerns regarding the interim DFARS rule (Case 2013-D018), which introduces new safeguarding and reporting requirements for institutions handling controlled defense information. COGR and AAU, representing leading research universities, highlight significant compliance bu
October 28, 2015- COGR Responds to Part 1 of the National Academies Report
The Council on Governmental Relations (COGR), representing major research universities, provides a detailed response to the National Academy of Sciences’ report on optimizing federal research regulations. COGR broadly supports recommendations aimed at streamlining grant application processes, harmonizing regulations across federal agencies, and reducing administrative burdens—particularly through
