Policy Perspective
Conflict of Interest Uniform Guidance
The document is a formal communication from the Council on Governmental Relations (COGR), an organization representing major research universities, to officials at the White House Office of Management and Budget (OMB). COGR expresses appreciation for prior collaborative efforts which have resulted in improvements to federal research administration policies. However, the letter outlines significant
COGR Comments on Proposed Changes to HHS Adoption of the UG_080316
The Council on Governmental Relations (COGR), representing over 190 research universities and affiliated institutions, submitted comments addressing proposed changes by the Department of Health and Human Services (HHS) concerning the adoption of the Office of Management and Budget's Uniform Guidance. The proposed rule would amend 45 CFR 75.414(c) to cap the indirect cost rate at 8% for certai
AAU APLU COGR TY to Lauer for disclosure policy withdrawal final
The Association of American Universities (AAU), the Association of Public and Land-grant Universities (APLU), and the Council on Governmental Relations (COGR) jointly submitted a letter to the National Institutes of Health (NIH) expressing concerns regarding NIH Notice NOT-OD-16-088, which proposed releasing the names of NIH-funded research project personnel through the NIH RePORTER system. The or
COGR_comments_to_NIH_on_the_proposed_policy_for_sharing_of_data
The Council on Governmental Relations (COGR), representing over 170 research universities and affiliated institutions, provided comprehensive feedback to the National Institutes of Health (NIH) regarding its proposed policy for sharing data from Genome-Wide Association Studies (GWAS). While COGR supports the NIH’s objective to enhance research through broad data availability, it raises substantive
Comment_letter_on_Department_of_Commerce_recommendations_on_deemed_export_controls
The comment letter, submitted by Katharina Phillips on behalf of the Council on Governmental Relations (COGR), addresses the Department of Commerce’s recommendations regarding deemed export controls as they pertain to fundamental research at U.S. universities. COGR, representing 160 research-intensive institutions, expresses strong concerns that implementing the Inspector General’s (IG) recommende
COGR_letter_on_the_DFARS_-_Export-Controlled_Information_and_Technology
The Council on Governmental Relations (COGR), representing research-intensive universities, submitted a detailed response to the U.S. Department of Defense (DOD) regarding revisions to the Defense Federal Acquisition Regulation Supplement (DFARS) on export-controlled information and technology. While COGR acknowledged significant improvements in the proposed DFARS rule—such as explicit references
March-in_Rights_Under_Bayh-Dole
The document is a formal letter from the Council on Governmental Relations (COGR), representing leading U.S. research universities and associated institutions, addressed to Dr. Mark Rohrbaugh, Director of the Office of Technology Transfer at the National Institutes of Health (NIH). The letter discusses the significance of march-in rights under the Bayh-Dole Act of 1980, emphasizing the Act's
Proposed_OMB_Guidelines_COGR_Comment
The document provides an overview and analysis of the Office of Management and Budget’s (OMB) final guidelines for peer review of influential scientific information, issued in December 2004 under the Information Quality Act. These guidelines are designed to improve the quality and reliability of scientific information used in federal agency decision-making. While universities are not directly affe
Proposed_Bulletin_on_Peer_Review_and_Information_Quality
The Council on Governmental Relations (COGR), representing over 150 leading research universities, provided detailed commentary on the Office of Management and Budget’s (OMB) proposed Bulletin on Peer Review and Information Quality. While COGR supports the foundational goals of objectivity, utility, quality, and integrity in federal agency information dissemination, the organization raises signifi
Food_and_Drug_Administration_Clinical_Misconduct_Guidance
The document is a formal comment submitted by the Council on Governmental Relations (COGR) regarding the Food and Drug Administration’s (FDA) interim rule for additional safeguards in clinical investigations involving children and FDA-regulated products. The letter commends the FDA for aligning its regulations (21 CFR Part 50 and 56) with those of the Department of Health and Human Services (DHHS)
