Comment Letter
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
COGR Submits Comments to the Small Business Administration in Response to Federal Register Notice
The Council on Governmental Relations (COGR), representing over 200 public and private research universities and affiliated institutions, submitted formal comments to the U.S. Small Business Administration (SBA) regarding a proposed rule to revise ownership, control, and subcontracting requirements for the 8(a) Business Development Program. COGR expresses support for the intent behind the proposed
Joint Comments from AAU, AAMC, APLU, ACE and COGR to NSF on Standard Disclosures
The memorandum, submitted jointly by several leading higher education and research associations, responds to the National Science Foundation’s request for public comment regarding the development of common disclosure forms for Biographical Sketch and Current and Pending Support within federal research applications, as mandated by NSPM-33. The associations commend federal efforts to harmonize and c
COGR Letter for Request for Comment for Common Disclosure Forms
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted detailed comments to the National Science Foundation regarding proposed common disclosure forms for Biographical Sketch and Current and Pending (Other) Support. COGR generally supports harmonizing federal disclosure requirements but highlights several challenges wit
COGR and ARIO Joint Response to ORI RFI Research Misconduct Policies
The Council on Governmental Relations (COGR) and the Association of Research Integrity Officers (ARIO) jointly responded to the Office of Research Integrity’s (ORI) request for input on revising the 2005 Public Health Service (PHS) Policies on Research Misconduct. Representing leading U.S. research universities and research integrity professionals, COGR and ARIO emphasized the importance of regula
COGR and AAMC Submit Joint Comment Letter to NIH on Cannabis RFI (NOT-AT-22-026)
The letter jointly submitted by the Association of American Medical Colleges (AAMC) and the Council on Governmental Relations (COGR) responds to an NIH Request for Information concerning barriers to researching the health effects of cannabis and its constituents. The organizations emphasize their support for increased federal efforts to assess the therapeutic potential of cannabinoid and cannabis-
COGR Submits Comments to OHRP in Response to HHS-OASH-2022-0011 "Use of a Single IRB for Cooperative Research" Draft Guidance
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated medical centers, submitted detailed feedback to the Office for Human Research Protections (OHRP) regarding the July 2022 draft guidance on the use of a Single Institutional Review Board (sIRB) for cooperative research. COGR commends the OHRP for addressing the complexities of sIRB implemen
Multi-Association Follow Up Letter to DoEd on Section 117
The letter from the American Council on Education (ACE), addressed to senior officials at the U.S. Department of Education (ED), conveys appreciation for updates regarding the management and reporting requirements of Section 117 of the Higher Education Act, which pertains to the disclosure of foreign gifts and contracts by higher education institutions. ACE acknowledges the helpfulness of the June
COGR Submits Comments in Response to NIH Guide Notice NOT-OD-22-131 Regarding Protecting Privacy When Sharing Human Research Participant Data
The Council on Governmental Relations (COGR), representing nearly 200 leading research institutions, submitted a response to the NIH's Draft Supplemental Information for Data Management and Sharing (NOT-OD-22-131). The COGR commends the NIH for its flexible and principle-based approach to protecting research participant privacy when sharing data, emphasizing the importance of considering both
