Policy Perspective
Official COGR Response to Final UG – February 13, 2015
The Council on Governmental Relations (COGR), representing over 190 research universities and affiliated institutions, submitted a formal response to the White House Office of Management and Budget (OMB) on February 13, 2015, regarding the implementation of Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200). COGR commended the OMB and t
January 22, 2015 - COGR Letter to OHRP on Draft Guidance on Disclosing Reasonably Foreseeable Risks in Research Evaluating Standards of Care
COGR sent a letter to the Office for Human Research Protections on draft guidance concerning disclosure of reasonably foreseeable risks in research evaluating standards of care.
January 16, 2015 - COGR Summary of Background and Technical Corrections to Final Uniform Guidance
The document prepared by David Kennedy and the COGR Costing Policies Committee provides a detailed overview of the background and technical corrections related to the implementation of the Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, commonly referred to as Uniform Guidance (UG). This guidance consolidated
January 16, 2015—Joint AAU and COGR Letter to NIST on Controlled Unclassified Information
The joint letter from the Association of American Universities (AAU) and the Council on Governmental Relations (COGR) to the National Institute of Standards and Technology (NIST) addresses concerns regarding the draft NIST Special Publication 800-171, which outlines security requirements for protecting controlled unclassified information (CUI) in nonfederal organizations. The authors acknowledge N
COGR Survey and the Role of the DS-2
A 2014 survey of the COGR membership indicated that the DS-2 disclosure statement requirement did little, at best, to enhance stewardship of federal funds.
NIH Definition of Clinical Trial Case Studies
The document presents a series of 23 case studies evaluating various types of research against the NIH definition of a clinical trial, providing rationales for each determination. It illustrates that a study qualifies as a clinical trial if it involves human subjects, prospective assignment to interventions (including behavioral, biomedical, or diagnostic procedures), and the assessment of health-
COFAR – COGR Review: OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
The document provides a detailed review and set of recommendations from the Council on Governmental Relations (COGR) regarding the implementation of the Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards—commonly known as the Uniform Guidance (UG). The content outlines specific regulatory sections discussed during
Addendum to COGR Response to Proposed UG – July 31, 2013
The Council on Governmental Relations (COGR), representing leading research universities, has submitted an addendum to comment on the proposed Uniform Guidance for federal grants as outlined in OMB-2013-0001. The letter acknowledges the federal initiative’s promise for meaningful grants reform, emphasizing the potential to provide regulatory relief and enhance the effectiveness and efficiency of f
COGR Response to Proposed UG – May 31, 2013
The document is a formal communication from the Council on Governmental Relations (COGR) to the U.S. Office of Management and Budget (OMB), offering comprehensive commentary on the proposed Uniform Guidance intended to streamline and update federal policies for grants, cooperative agreements, cost principles, and administrative requirements. Representing major research universities and institution
