Policy Perspective
COGR Responds to OMB's Request to Provide Data-driven Evidence to Support Modifications to 2 CFR Chapter 2, Part 200 (2 CFR 200) of the Uniform Guidance (UG)
The document is a formal letter from the Council on Governmental Relations (COGR) to a policy analyst at the Office of Federal Financial Management, Office of Management and Budget (OMB), addressing proposed revisions to 2 CFR Chapter 2, Part 200 (Uniform Guidance) as it relates to federally funded research at academic institutions. Drawing on recent surveys and studies, COGR advocates for three p
COGR Submits Comments in Response to NASA’s RFI: Freedom of Information Act (FOIA) Disclosures: Proposed NASA Grant Application Marking for FOIA Disclosure-Exempt Material Published in the Federal Register
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and related entities, responded to NASA’s June 2023 Request for Information regarding proposed changes to the designation of confidential business information (CBI) in NASA grant applications for Freedom of Information Act (FOIA) purposes. COGR acknowledged the importance of FOIA and its exemptions but e
Overview of Department of Defense Statement on Countering Unwanted Foreign Influence in Department-Funded Research Institutions of Higher Education
In July 2023, the Department of Defense (DOD) released a suite of materials establishing new requirements and processes to identify and mitigate risks associated with unwanted foreign influence, conflicts of interest, and conflicts of commitment in DOD-funded fundamental research at higher education institutions. In support of National Security Presidential Memorandum-33 and relevant federal statu
COGR Submits Joint Association Response to OMB on Comment Request; iEdison System
The letter, submitted by COGR and other higher education associations, expresses strong support for the continued redesign, expansion, and harmonization of the iEdison invention reporting system across all federal agencies, as outlined in OMB Control No. 0693-0090. The associations highlight the benefits of uniform reporting requirements under the Bayh-Dole Act, including reduced compliance burden
COGR Submits Comment Letter in Response to Notice to Announce NIH Updated Policy Guidance for Subaward/Consortium Written Agreements (88 FR 36603)
The Council on Governmental Relations (COGR), representing over 200 research universities and affiliated institutions in the United States, submitted formal comments to the NIH concerning the recently updated policy guidance on subaward/consortium written agreements, specifically the provision requiring foreign subrecipients to provide prime recipients with all lab notebooks, data, and documentati
COGR Responds to NSF’s Request for Response to Dear Colleague Letter: Development of the U.S. Research Security and Integrity Information Sharing Analysis Organization
COGR submitted a letter to the National Science Foundation's (NSF) regarding the proposed Research Security and Integrity Information Sharing Analysis Organization (RSI-ISAO). COGR expresses strong support for the development of RSI-ISAO, emphasizing the need for trust, transparency, and voluntary institutional participation without an enforcement or intermediary role. The letter highlights the im
COGR Responds to the National Science Foundation Proposal/Award; Information— NSF Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 24-1) Comment Request
The Council on Governmental Relations (COGR), representing over 200 research universities and institutes, provided detailed feedback to the National Science Foundation (NSF) on the proposed revisions to the Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 24-1). COGR commends NSF’s efforts toward responsiveness, transparency, and stakeholder engagement, but outlines several areas
The COGR 2023 F&A Survey Preliminary Results: June 2023 Meeting
The COGR 2023 F&A Survey provides a comprehensive overview of current practices, trends, and challenges related to Facilities and Administrative (F&A) cost rates at U.S. research institutions. Conducted between January and April 2023 with 119 respondents, the survey serves as both a benchmarking tool and an advocacy resource. Its findings reveal a diverse respondent profile, predominantly
COGR Responds to OSTP Request for Information: NSPM 33 Research Security Programs Standard Requirement (88 FR 14187)
COGR submitted comments on the proposed OSTP Research Security Program Standard Requirements, emphasizing the need for standards that are risk-based, consistent across all agencies, and clearly defined to avoid unnecessary burdens and confusion. COGR advocates for streamlined compliance procedures, clearer definitions, and more flexibility for institutions, while urging that compliance requirement
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),
