Comment Letter
COGR Submits Joint Association Response to OMB on Comment Request; iEdison System
The letter, submitted by COGR and other higher education associations, expresses strong support for the continued redesign, expansion, and harmonization of the iEdison invention reporting system across all federal agencies, as outlined in OMB Control No. 0693-0090. The associations highlight the benefits of uniform reporting requirements under the Bayh-Dole Act, including reduced compliance burden
COGR Submits Comment Letter in Response to Notice to Announce NIH Updated Policy Guidance for Subaward/Consortium Written Agreements (88 FR 36603)
The Council on Governmental Relations (COGR), representing over 200 research universities and affiliated institutions in the United States, submitted formal comments to the NIH concerning the recently updated policy guidance on subaward/consortium written agreements, specifically the provision requiring foreign subrecipients to provide prime recipients with all lab notebooks, data, and documentati
COGR Responds to NSF’s Request for Response to Dear Colleague Letter: Development of the U.S. Research Security and Integrity Information Sharing Analysis Organization
COGR submitted a letter to the National Science Foundation's (NSF) regarding the proposed Research Security and Integrity Information Sharing Analysis Organization (RSI-ISAO). COGR expresses strong support for the development of RSI-ISAO, emphasizing the need for trust, transparency, and voluntary institutional participation without an enforcement or intermediary role. The letter highlights the im
COGR Responds to the National Science Foundation Proposal/Award; Information— NSF Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 24-1) Comment Request
The Council on Governmental Relations (COGR), representing over 200 research universities and institutes, provided detailed feedback to the National Science Foundation (NSF) on the proposed revisions to the Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 24-1). COGR commends NSF’s efforts toward responsiveness, transparency, and stakeholder engagement, but outlines several areas
COGR Participates in Joint Association Response to Comment Request; Agency Information Collection Activities; Submission to OMB for Review and Approval; Foreign Gifts and Contracts Disclosures
The letter, submitted by the American Council on Education and numerous higher education associations, provides formal feedback on the U.S. Department of Education’s (ED) proposed Information Collection Request (ICR) concerning the reporting of foreign gifts and contracts under Section 117. While acknowledging the significance of research security and transparency, as well as recent improvements s
COGR Responds to OSTP Request for Information: NSPM 33 Research Security Programs Standard Requirement (88 FR 14187)
COGR submitted comments on the proposed OSTP Research Security Program Standard Requirements, emphasizing the need for standards that are risk-based, consistent across all agencies, and clearly defined to avoid unnecessary burdens and confusion. COGR advocates for streamlined compliance procedures, clearer definitions, and more flexibility for institutions, while urging that compliance requirement
COGR, AAU, and AUTM Submit Joint Association Letter on COVID-19 Diagnostics and Therapeutics: Supply, Demand, and TRIPS Agreement Flexibilities
The letter, submitted jointly by the Association of American Universities (AAU), the Council on Government Relations (COGR), and AUTM, addresses the U.S. International Trade Commission in relation to Investigation No. 332-596, focusing on COVID-19 diagnostics, therapeutics, and the possible expansion of the TRIPS Agreement waiver. The associations, representing leading American research universiti
COGR's Response to Request for Information (RFI) on Update to NOT-OD-05-034 Guidance on Prompt Reporting of Noncompliances to OLAW (NOT-OD-23-063)
COGR submitted a letter to the National Institutes of Health’s Office of Laboratory Animal Welfare (OLAW) regarding the proposed update to guidance on prompt reporting of noncompliance in animal research. COGR acknowledges the importance of clear and unambiguous reporting standards, which balance the protection of animal welfare with minimizing unnecessary administrative burden for researchers. Wh
COGR Responds to the NIH Plan to Enhance Public Access to the Results of NIH-Supported Research [NOT-OD-23-091]
This document is a formal response from the Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, to the National Institutes of Health’s Request for Information regarding its plan to enhance public access to the results of NIH-supported research. COGR expresses support for the OSTP directive that increases access to federally funded
COGR's Response to Request for Information (RFI): Re-envisioning U.S. Postdoctoral Research Training and Career Progression within the Biomedical Research Enterprise [NOT-OD-23-084]
The Council on Governmental Relations (COGR), representing more than 200 U.S. research universities and affiliated institutions, submitted this response to the NIH’s Request for Information regarding the enhancement of postdoctoral research training and career progression in the biomedical field. COGR’s comments focus on several key policy areas to improve postdoctoral training pathways. It recomm
