Policy Perspective
Research Security and the Cost of Compliance—Phase I Report, Disclosure Requirements Now Available
COGR conducted Phase I of the survey described in this report to quantify the considerable time and resources (financial and otherwise) that research institutions have invested (or will invest) to achieve compliance with the Disclosure Requirements. COGR is providing this Phase I report to research institutions and federal research funding agencies in the hope that it will both encou
COGR Submits Comments to the Small Business Administration in Response to Federal Register Notice
The Council on Governmental Relations (COGR), representing over 200 public and private research universities and affiliated institutions, submitted formal comments to the U.S. Small Business Administration (SBA) regarding a proposed rule to revise ownership, control, and subcontracting requirements for the 8(a) Business Development Program. COGR expresses support for the intent behind the proposed
COGR Letter for Request for Comment for Common Disclosure Forms
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted detailed comments to the National Science Foundation regarding proposed common disclosure forms for Biographical Sketch and Current and Pending (Other) Support. COGR generally supports harmonizing federal disclosure requirements but highlights several challenges wit
COGR and ARIO Joint Response to ORI RFI Research Misconduct Policies
The Council on Governmental Relations (COGR) and the Association of Research Integrity Officers (ARIO) jointly responded to the Office of Research Integrity’s (ORI) request for input on revising the 2005 Public Health Service (PHS) Policies on Research Misconduct. Representing leading U.S. research universities and research integrity professionals, COGR and ARIO emphasized the importance of regula
NSPM-33 Implementation Guidance Disclosure Requirements Standardization Talking Points for Institutions
The proposed Standardized Disclosure Forms
COGR and AAMC Submit Joint Comment Letter to NIH on Cannabis RFI (NOT-AT-22-026)
The letter jointly submitted by the Association of American Medical Colleges (AAMC) and the Council on Governmental Relations (COGR) responds to an NIH Request for Information concerning barriers to researching the health effects of cannabis and its constituents. The organizations emphasize their support for increased federal efforts to assess the therapeutic potential of cannabinoid and cannabis-
DOE vs. PHS FCOI Comparison Document
This document presents a detailed comparative analysis of the Department of Energy’s (DOE) Interim Conflict of Interest (COI) Policy for Financial Assistance and the Public Health Service (PHS) regulations for Promoting Objectivity in Research (42 CFR Part 50, Subpart F), conducted by COGR as of August 27, 2022. The analysis uses the DOE policy as the base text, highlighting differences and alignm
COGR Submits Comments to OHRP in Response to HHS-OASH-2022-0011 "Use of a Single IRB for Cooperative Research" Draft Guidance
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated medical centers, submitted detailed feedback to the Office for Human Research Protections (OHRP) regarding the July 2022 draft guidance on the use of a Single Institutional Review Board (sIRB) for cooperative research. COGR commends the OHRP for addressing the complexities of sIRB implemen
Multi-Association Follow Up Letter to DoEd on Section 117
The letter from the American Council on Education (ACE), addressed to senior officials at the U.S. Department of Education (ED), conveys appreciation for updates regarding the management and reporting requirements of Section 117 of the Higher Education Act, which pertains to the disclosure of foreign gifts and contracts by higher education institutions. ACE acknowledges the helpfulness of the June
Roles and Responsibilities: Considerations for Institutions
The document provides comprehensive guidance for institutions preparing to comply with the NIH’s Final Policy for Data Management and Sharing (DMS), effective January 2023. It emphasizes the cultural shift required to prioritize data sharing throughout the research lifecycle, aiming to enhance transparency, reproducibility, and the efficient use of taxpayer-funded research. Institutions are advise
