Policy Perspective
COGR Submits Comments to GSA Regarding the Transition of the Federal Audit Clearinghouse
COGR provided comments to the GSA regarding the transition of the Federal Audit Clearinghouse from the U.S. Census Bureau to the GSA.
COGR Requests a 30-Day Extension to Respond to OMB's RFI
COGR requested a 30-day extension to respond to OMB’s RFI regarding updates to 2 CFR Part 200, Uniform Guidance.
COGR Responds to the Request for Information: Clinical Research Infrastructure and Emergency Clinical Trials
The Council on Governmental Relations (COGR), representing over 200 U.S. research institutions, submitted a detailed response to the White House Office of Science and Technology Policy's Request for Information on enhancing clinical research infrastructure for emergency clinical trials (ECR). Drawing on extensive experience from the COVID-19 pandemic, COGR emphasized the necessity for rapid,
COGR Responds to HHS Notice of Proposed Rulemaking “Confidentiality of Substance Abuse Disorder Patient Records”
COGR, representing over 200 U.S. research institutions, submitted comments on the Department of Health and Human Services' proposed rule to align the confidentiality regulations for substance abuse disorder patient records (42 CFR Part 2) with HIPAA. COGR supports the alignment to reduce dual compliance burdens and enhance research capabilities, advocating for clearer allowances for creating de-id
COGR Submits Letter to HHS on Timely Establishment of Indirect Cost and Fringe Benefit Rate Agreements
COGR submitted a letter to Mak Karim, the National Director for Cost Allocation Services at the U.S. Department of Health and Human Services. In the letter, COGR requests assistance to facilitate improvements in the speed of the review and approval process associated with indirect cost and fringe benefit rates.
COGR Submits Letter to Dr. Tabak on the NIH Modular Grant Application and Award Process
The letter, sent by the Council on Governmental Relations (COGR) to Dr. Lawrence A. Tabak, Acting Director of the National Institutes of Health (NIH), highlights concerns with the current limitations of the NIH Modular Grant Application and Award process. COGR acknowledges the positive impact and original intent of the modular grant system, introduced in 1998 to reduce administrative burden and fo
COGR Submits Comments to the Small Business Administration in Response to Federal Register Notice
The Council on Governmental Relations (COGR), representing over 200 public and private research universities and affiliated institutions, submitted formal comments to the U.S. Small Business Administration (SBA) regarding a proposed rule to revise ownership, control, and subcontracting requirements for the 8(a) Business Development Program. COGR expresses support for the intent behind the proposed
COGR Letter for Request for Comment for Common Disclosure Forms
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted detailed comments to the National Science Foundation regarding proposed common disclosure forms for Biographical Sketch and Current and Pending (Other) Support. COGR generally supports harmonizing federal disclosure requirements but highlights several challenges wit
COGR and ARIO Joint Response to ORI RFI Research Misconduct Policies
The Council on Governmental Relations (COGR) and the Association of Research Integrity Officers (ARIO) jointly responded to the Office of Research Integrity’s (ORI) request for input on revising the 2005 Public Health Service (PHS) Policies on Research Misconduct. Representing leading U.S. research universities and research integrity professionals, COGR and ARIO emphasized the importance of regula
COGR and AAMC Submit Joint Comment Letter to NIH on Cannabis RFI (NOT-AT-22-026)
The letter jointly submitted by the Association of American Medical Colleges (AAMC) and the Council on Governmental Relations (COGR) responds to an NIH Request for Information concerning barriers to researching the health effects of cannabis and its constituents. The organizations emphasize their support for increased federal efforts to assess the therapeutic potential of cannabinoid and cannabis-