Comment Letter
COGR Letter to OEI HHS-OIG
The letter from Matt Owens, President of the Council on Governmental Relations (COGR), addresses the Office of Inspector General (OIG) at the U.S. Department of Health and Human Services (HHS) following a meeting on January 30, 2024, regarding the NIH Recipient Institutions’ Reporting of Monetary Donations that Support Research Survey. COGR thanks the OIG representatives for their engagement and d
COGR Joins a Multi-Association Extension Request to NIST for the RFI Regarding the Draft Interagency Guidance Framework for Considering the Exercise of March-In Rights (Docket No.: 230831-0207)
The letter, sent by major associations representing research universities and medical colleges, requests a 90-day extension to the public comment period on the National Institute of Standards and Technology's draft interagency guidance framework regarding the exercise of march-in rights under the Bayh-Dole Act. The organizations express concern that the proposed changes significantly depart from l
COGR Responds to NIH Request for Information (RFI) on Proposed Guidance to Assured Institutions on Cephalopod Care and Use (NOT-OD-23-176)
COGR submitted a response to the NIH Office of Laboratory Animal Welfare’s (OLAW) Request for Information on Proposed Guidance to Assured Institutions concerning the care and use of cephalopods in research. While COGR supports the advancement of animal welfare and recognizes the evolving scientific understanding of cephalopod care, it expresses significant concerns about the scope and basis of OLA
COGR Submits Comments to ORI on Public Health Service Policies on Research Misconduct Notice of Proposed Rulemaking
The Council on Governmental Relations (COGR), representing over 200 major U.S. research universities and affiliates, submits extensive comments regarding the Office of Research Integrity's (ORI) proposed revisions to the Public Health Service (PHS) Policies on Research Misconduct. COGR expresses significant concerns that the proposed regulations, intended to clarify and streamline the researc
COGR Joins C4IP in Urging the Biden Administration to Oppose the Proposed WTO IP Waiver for Covid-19 Therapeutics and Diagnostics
The letter, dated December 4, 2023, is addressed to President Joseph R. Biden by the Council for Innovation Promotion, a bipartisan group comprised of former senior government officials, university technology transfer experts, and leaders from trade and health sectors. The signatories urge President Biden to oppose the World Trade Organization's proposed waiver of intellectual property (IP) r
COGR Responds to OMB's NPRM on Guidance for Grants & Agreements "Uniform Guidance"
The document is a formal response from the Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, to the Office of Management and Budget’s (OMB) proposed revisions to 2 CFR Chapters 1 and 2. COGR commends OMB for its transparency and dedication throughout the rulemaking process but highlights several areas where the proposed changes
COGR Submits Joint Association Request for Extension of Comment Period for Oct. 6, 2023, NPRM on PHS Policies on Research Misconduct (88 FR 69583)
The memorandum, sent jointly by several major associations representing higher education and research institutions, addresses the Office of Research Integrity (ORI) regarding the recently published Notice of Proposed Rulemaking (NPRM) on Public Health Service Policies on Research Misconduct. The associations express their commitment to upholding research integrity and acknowledge ORI’s efforts to
COGR Responds to Request for Information (RFI) on an Update to the Current OLAW Guidance Disclaimer
COGR responded to the Office of Laboratory Animal Welfare’s (OLAW) Request for Information regarding its proposed guidance disclaimer, expressing concern that the current wording incorrectly suggests OLAW can expand regulatory requirements beyond Congressional authority. COGR recommends that OLAW revise the disclaimer to clearly state that guidance documents are recommendations, not binding requir
COGR Responds to RFI on Potential Changes to the Policies for Oversight of Dual Use Research of Concern (DURC) and the Potential Pandemic Pathogen Care and Oversight (P3CO) Policy Framework
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and related institutions, submitted detailed comments to the Office of Science and Technology Policy (OSTP) regarding proposed changes to the oversight policies for Dual Use Research of Concern (DURC) and Potential Pandemic Pathogen Care and Oversight (P3CO). While COGR emphasizes its strong commitment t
COGR Responds to RFI on Flexibilities for Streamlining IACUC Review of Protocols and Significant Changes (NOT-OD-23-152)
COGR submitted formal comments in response to the NIH’s Request for Information (RFI) regarding flexibilities for streamlining Institutional Animal Care and Use Committee (IACUC) review processes. COGR emphasizes the importance of maintaining animal welfare and research integrity while advocating for efficient regulatory frameworks that minimize unnecessary administrative burdens, as mandated by t
