Policy Perspective
COGR Submits Comments to OMB on 2 CFR 200 Subpart F - Audit Requirements Appendix XI - Compliance Supplement 2021
The Council on Governmental Relations (COGR), representing over 190 member institutions, submitted comments to the Office of Management and Budget (OMB) regarding the 2021 Compliance Supplement for 2 CFR Part 200, Subpart F. The correspondence, addressed to Mr. Gilbert Tran, thanks OMB for its efforts and highlights several concerns centered on audit requirements for federal grants, particularly i
COGR Submits Joint Comments with AUTM and Bayh-Dole Coalition to DOE on Exceptional Circumstances Determination
The letter addresses concerns from the Bayh-Dole Coalition and allied organizations regarding the U.S. Department of Energy’s (DOE) recent “determination of exceptional circumstances” (DEC), which aims to promote domestic development of DOE-funded inventions. While the coalition appreciates the DOE's efforts to prevent the off-shoring of strategically important technologies, it raises signifi
F&A Cost Rates and Reimbursement Pressures Under COVID-19: Maintaining a Fair and Reliable System
The document, prepared by the Council on Governmental Relations (COGR), examines the significant challenges and emerging considerations affecting Facilities and Administrative (F&A) cost rates and reimbursements for research institutions during and after the COVID-19 pandemic. It details how the pandemic has disrupted traditional processes for developing F&A cost rate proposals, especially
