Policy Perspective
NIH’s Implementation of the U.S. Government Policy on Dual Use Research of Concern and Pathogens with Enhanced Pandemic Potential
The document outlines the implications and implementation procedures stemming from the newly issued NIH policy (NOT-OD-25-061) on oversight of Dual Use Research of Concern (DURC) and Pathogens with Enhanced Pandemic Potential (PEPP). Effective May 6, 2025, this policy consolidates and supersedes previous federal regulations, broadening the range of biological agents and experimental categories req
Results from COGR/ARIO Survey of Research Integrity Officials on Final ORI Research Misconduct Rule
The document presents the results of a joint survey conducted by the Council on Governmental Relations (COGR) and the Association of Research Integrity Officers (ARIO) between October and November 2024. The survey targeted research integrity officials at institutions responsible for implementing the revised Public Health Service (PHS) Policies on Research Misconduct, following the publication of a
Cost of Compliance: Results from the COGR Survey on the Cost of Complying with the New NIH DMS Policy
The document summarizes the findings from a 2022 COGR survey assessing the financial and administrative burdens imposed by the new NIH Data Management and Sharing (DMS) Policy, effective January 2023, which expanded data management requirements to all NIH-funded research projects generating scientific data. The survey, completed by 34 institutions (29 mid-size to large and 5 smaller institutions),
Research Security and the Cost of Compliance—Phase I Report, Disclosure Requirements Now Available
COGR conducted Phase I of the survey described in this report to quantify the considerable time and resources (financial and otherwise) that research institutions have invested (or will invest) to achieve compliance with the Disclosure Requirements. COGR is providing this Phase I report to research institutions and federal research funding agencies in the hope that it will both encou
COGR 2018 SURVEY REPORT ON INSTITUTIONAL RESOURCES FOR PROMOTING RESEARCH QUALITY
The 2018 COGR Survey Report examines how leading U.S. research universities, medical centers, and research institutes support research quality, rigor, and reproducibility, in response to heightened attention from federal agencies such as NIH and NSF. Drawing on survey responses from approximately one-third of COGR’s membership, the report finds that all responding institutions provide at least som
The Politics of Indirect Costs
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Appendix B Data: 2017 F&A Survey
The Appendix B – Survey Data Sheet details the results of a 2017 survey administered by the Council on Governmental Relations, focusing on institutional practices related to federal rate agreements, clinical trials, and negotiation experiences. Of the 145 institutions responding, 70% were public and 30% private, with a significant majority (89%) designating the Department of Health and Human Servi
2017 Survey of Facilities & Administrative (F&A) Rates Executive Summary
The Council on Governmental Relations (COGR), representing 190 leading research universities and institutions conducting over $60 billion in annual research, conducted its 2017 Survey of Facilities & Administrative (F&A) Rates to analyze trends and understandings in the reimbursement of indirect research costs. F&A costs, also referred to as indirect or research operating costs, are es
Analysis of Common Rule Comments
In January 2016, COGR staff and university and association volunteers began an analysis of the 2,186 comments submitted to regulations.gov in response to the Notice of Proposed Rulemaking (NPRM) on the Federal Policy for the Protection of Human Subjects (Common Rule).
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.
