Comment Letter
COGR Submits Joint Association Request to OSTP for Listening Sessions on Research Security Programs Standards
The letter, addressed to Stacy Murphy of the Office of Science and Technology Policy (OSTP), is a formal request from major organizations representing the higher education and research community regarding the draft standards for research security programs under NSPM-33. The signatories commend the OSTP for its work and the ample opportunity for public comment, but express the need for additional e
COGR Responds to OMB's RFI: Uniform Guidance (2 CFR 200)
COGR has posted its Letter to OMB, in response to OMB’s Request for Information (RFI) – Uniform Guidance. We expect OMB to review responses from all stakeholders and publish proposed revisions to the Uniform Guidance later in 2023.
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
