Policy Perspective
COGR Submits Comments in Response to ANPRM Entitled Wild and Exotic Animal Handling, Training of Personnel Involved with Public Handling of Wild and Exotic Animals, and Environmental Enrichment for Species
The Council on Governmental Relations (COGR), representing over 200 research universities and affiliated institutions, submitted comments in response to the USDA Animal and Plant Health Inspection Service's (APHIS) advance notice of proposed rulemaking concerning wild and exotic animal handling, personnel training, and, notably, environmental enrichment standards for species covered under the
COGR Signs on to Multi-Association Letter to DoEd Regarding Foreign Gift & Contract Disclosures (ED-2022-SCC-0159)
The letter, submitted by the American Council on Education and a coalition of higher education associations, provides detailed comments to the U.S. Department of Education regarding its proposed Information Collection Request (ICR) related to reporting foreign gifts and contracts under Section 117 of the Higher Education Act. The organizations affirm their commitment to transparency and compliance
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's NIH Data Management and Sharing Readiness Guide: Chapter 4 Part II, Project-Based and Institutional Cost Considerations - Budgeting & Costing
This document, Chapter 4 Part II of the COGR NIH DMS Readiness Guide, addresses the key budgeting and costing considerations associated with implementing the NIH Data Management and Sharing (DMS) Policy at academic and research institutions. It emphasizes the importance of carefully identifying, budgeting, and managing both direct and indirect DMS-related costs in grant applications. The guide out
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 Review of the Final NIH Policy for Data Management and Sharing: Budgeting & Costing
The COGR Review of the Final NIH Policy for Data Management and Sharing provides a thorough analysis of the challenges institutions and researchers face regarding budgeting and costing in compliance with the new NIH policy effective January 25, 2023. The document acknowledges that while the policy aims to enhance robust data sharing and scientific advancement, it introduces significant new complia
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
