Policy Perspective
Summary of Changes to the Common Rule
The Council on Governmental Relations provided a detailed overview of the final revisions to the federal Common Rule, which governs the protection of human research subjects, as published in early 2017. The majority of the new regulations take effect on January 19, 2018, with the requirement for single IRB review of multisite cooperative research deferred to January 20, 2020. Significant updates i
Letter to DOE Re: January 18, 2017 Minor Change to DOE Order 142.3A, Unclassified Foreign Visitors and Assignments Program
The Council on Governmental Relations (COGR), a consortium representing leading research institutions, addressed a letter on February 1, 2017, to Dr. Adam Cohen, Deputy Undersecretary in the U.S. Department of Energy (DOE). The letter expresses gratitude for recent amendments to DOE Order 142.3A, which pertains to the Unclassified Foreign Visitors and Assignments Program. Specifically, COGR commen
Joint AAU COGR Letter to DOE Re: Request for Limited Exemption from DOE Order 142.3A
The letter, jointly authored by the Council on Governmental Relations (COGR) and the Association of American Universities (AAU), addresses Dr. Adam Cohen of the U.S. Department of Energy (DOE), expressing appreciation for his recent discussion on the application and interpretation of DOE Order 142.3A with regard to foreign nationals participating in DOE/NETL-funded fundamental research at universi
NPRM Public Comments Overview
The document summarizes public feedback on the Notice of Proposed Rulemaking (NPRM) for revisions to the Common Rule, as reviewed in May 2016. Over 2,100 comments were received, a significant increase from earlier rounds, with the majority submitted by individuals without clear affiliations. Institutions, particularly medical and academic entities, also participated. Commenters raised concerns abo
COGR Supports Cures Legislation in Letter to Senate HELP Staff
The document is a formal letter from the Council on Governmental Relations (COGR), representing over 190 prominent research universities and related institutions, addressed to Senators Lamar Alexander and Patty Murray of the Senate Health, Education, Labor, and Pensions Committee. COGR expresses strong support for the advancement of the 21st Century Cures legislation, particularly commending provi
Education Title IV Audit Concerns
This document is a formal letter from four leading professional organizations—AICPA, COGR, NACUBO, and NASACT—addressed to the U.S. Office of Management and Budget (OMB) in response to the U.S. Department of Education’s (ED) recent policy requiring a separate annual compliance audit for Title IV Student Aid Programs, regardless of the programs’ risk status under existing single audit regulations.
COGR Submits Joint Letter with AAU, APLU, and AAMC Requesting Extension to NIH sIRB Policy Implementation
The letter, jointly authored by the leadership of the Council on Governmental Relations (COGR), Association of American Universities (AAU), Association of Public and Land-grant Universities (APLU), and the Association of American Medical Colleges (AAMC), addresses the National Institutes of Health (NIH) concerning the impending implementation of the NIH Policy on the Use of a Single Institutional