Policy Perspective
F&A Frequently Asked Questions
The document provides an in-depth explanation of Facilities and Administrative (F&A) costs—also known as indirect costs—associated with federally sponsored research at U.S. universities. F&A costs are essential for maintaining the infrastructure and administrative support required to conduct high-quality research, including laboratory facilities, data management, compliance with health and
F&A Talking Points
The document addresses concerns raised by federal officials and the media regarding the proportion of National Institutes of Health (NIH) grant funding allocated to indirect, or facilities and administrative (F&A), costs—often referred to as overhead. It clarifies that both direct and indirect costs together represent the full expenses of conducting federally sponsored research. F&A costs
F&A Primer
The document provides a thorough overview of Facilities and Administrative (F&A) costs, also known as research operating or indirect costs, within the context of sponsored research at universities. It outlines the distinction between direct costs—such as salaries, lab supplies, and equipment, which are the primary focus of research funding—and F&A costs, which are essential infrastructural
Research Regulatory Reform: Recent Legislation and the New Administration
The document provides a detailed overview of recent legislative and executive actions impacting federal research regulation as of early 2017, focusing on their implications for regulatory reform in the research sector. It highlights key legislation, notably the 21st Century Cures Act, the American Innovation and Competitiveness Act (AICA), and the National Defense Authorization Act (NDAA), each pr
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
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
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 Proposed FAQs on Uniform Guidance to OMB
The document is a formal letter from the Council on Governmental Relations (COGR), an association representing major research universities, addressed to Mr. Gilbert Tran at the White House Office of Management and Budget’s Office of Federal Financial Management. Dated August 26, 2016, the letter provides a set of proposed Frequently Asked Questions (FAQs) intended to clarify sections of the Unifor
COGR/AAU/APLU Submit Joint Letter Thanking NIH for Rescinding NOT-OD- 16-088
The Association of American Universities (AAU), Association of Public and Land-grant Universities (APLU), and Council on Governmental Relations (COGR) collectively addressed a letter to Dr. Michael S. Lauer of the National Institutes of Health (NIH) expressing concerns regarding the proposed policy (NOT-OD-16-088) to publicly release the names of NIH-funded research project personnel via the NIH R
