Comment Letter
Comment_letter_on_Department_of_Commerce_recommendations_on_deemed_export_controls
The comment letter, submitted by Katharina Phillips on behalf of the Council on Governmental Relations (COGR), addresses the Department of Commerce’s recommendations regarding deemed export controls as they pertain to fundamental research at U.S. universities. COGR, representing 160 research-intensive institutions, expresses strong concerns that implementing the Inspector General’s (IG) recommende
COGR_letter_on_the_DFARS_-_Export-Controlled_Information_and_Technology
The Council on Governmental Relations (COGR), representing research-intensive universities, submitted a detailed response to the U.S. Department of Defense (DOD) regarding revisions to the Defense Federal Acquisition Regulation Supplement (DFARS) on export-controlled information and technology. While COGR acknowledged significant improvements in the proposed DFARS rule—such as explicit references
March-in_Rights_Under_Bayh-Dole
The document is a formal letter from the Council on Governmental Relations (COGR), representing leading U.S. research universities and associated institutions, addressed to Dr. Mark Rohrbaugh, Director of the Office of Technology Transfer at the National Institutes of Health (NIH). The letter discusses the significance of march-in rights under the Bayh-Dole Act of 1980, emphasizing the Act's
Proposed_OMB_Guidelines_COGR_Comment
The document provides an overview and analysis of the Office of Management and Budget’s (OMB) final guidelines for peer review of influential scientific information, issued in December 2004 under the Information Quality Act. These guidelines are designed to improve the quality and reliability of scientific information used in federal agency decision-making. While universities are not directly affe
Proposed_Bulletin_on_Peer_Review_and_Information_Quality
The Council on Governmental Relations (COGR), representing over 150 leading research universities, provided detailed commentary on the Office of Management and Budget’s (OMB) proposed Bulletin on Peer Review and Information Quality. While COGR supports the foundational goals of objectivity, utility, quality, and integrity in federal agency information dissemination, the organization raises signifi
Food_and_Drug_Administration_Clinical_Misconduct_Guidance
The document is a formal comment submitted by the Council on Governmental Relations (COGR) regarding the Food and Drug Administration’s (FDA) interim rule for additional safeguards in clinical investigations involving children and FDA-regulated products. The letter commends the FDA for aligning its regulations (21 CFR Part 50 and 56) with those of the Department of Health and Human Services (DHHS)
National_Science_Foundation_Revision_to_Research_Misconduct
The document is a formal correspondence from the Council on Governmental Relations (COGR), represented by President Katharina Phillips, to Anita Eisenstadt, Assistant General Counsel at the National Science Foundation (NSF). Dated February 20, 2002, the letter addresses the NSF's proposed revision to its Research Misconduct rule (45 CFR Part 689), which aligns NSF’s regulations with the Feder
Modifications_on_HIPAA_Privacy_Rules
The document is a formal letter from the Council on Governmental Relations (COGR), representing over 145 research-intensive U.S. universities, addressed to Secretary Tommy G. Thompson of the U.S. Department of Health and Human Services (HHS). Authored by Katharina Phillips, the letter responds to proposed modifications of the HIPAA Privacy Rule, specifically as they relate to research activities i
Department_of_State_Amendments_to_ITAR
The Council on Governmental Relations (COGR) submitted formal comments to the U.S. Department of State regarding recent amendments to the International Traffic in Arms Regulations (ITAR) as published in March 2002. COGR expresses appreciation for the State Department’s reaffirmation that fundamental research at universities and public domain information are not subject to ITAR restrictions, consis
COGR -DOL-OT (3)
The document is a formal letter from the Council on Governmental Relations (COGR), an association of 190 prominent research universities and affiliated academic institutions, addressed to the U.S. Department of Labor in response to proposed changes regarding overtime pay exemptions under the Fair Labor Standards Act (FLSA). COGR expresses concern over the Department of Labor’s proposal to signific
