Policy Perspective
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COGR Submits Comments to OHRP in Response to HHS-OASH-2022-0011 "Use of a Single IRB for Cooperative Research" Draft Guidance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centers, submitted detailed feedback to the Office for Human Research Protections (OHRP) regarding the July 2022 draft guidance on the use of a Single Institutional Review Board (sIRB) for cooperative research.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
Technology Transfer in U.S. Research Universities: Dispelling Common Myths (Updated August 2022)
This document, published by COGR, systematically addresses and dispels common misconceptions about technology transfer activities within U.S. research universities. It presents evidence and expert analysis to refute the belief that such activities detract from universities' core missions, generate excessive revenue, or create significant conflicts of interest, emphasizing instead the societal, eco
Chapter 2: NIH Data Management and Sharing Policy Matrix
COGR has published Version 3.0 of the NIH Data Management and Sharing Policy Matrix, which serves as Chapter 2 of COGR’s NIH DMS Readiness Guide
COGR Submits Comments in Response to NIH Guide Notice NOT-OD-22-131 Regarding Protecting Privacy When Sharing Human Research Participant Data
The Council on Governmental Relations (COGR), representing nearly 200 leading research institutions, submitted a response to the NIH's Draft Supplemental Information for Data Management and Sharing (NOT-OD-22-131). The COGR commends the NIH for its flexible and principle-based approach to protecting research participant privacy when sharing data, emphasizing the importance of considering both
COGR Submits Comments to NSF on the Draft PAPPG (NSF 23-1)
The Council on Governmental Relations (COGR), representing 200 major U.S. research institutions, submitted formal comments to the National Science Foundation (NSF) on the draft Proposal and Award Policies and Procedures Guide (PAPPG, NSF 23-1). COGR commends NSF for its technological advancements, such as implementing Research.gov and retiring Fastlane.gov, but raises concerns about duplicative sy
Research Security & the ROI Results from COGR’s Research Security Costing Model Survey: June 2022 Meeting
The document presents a summary of the COGR’s Research Security Costing Model Survey, which aimed to assess the financial and operational impacts of federal research security requirements in higher education institutions. The survey involved 25 institutions, predominantly universities with academic medical centers, encompassing a broad research portfolio including fundamental, export controlled, a
Final NIH Policy for Data Management and Sharing Briefing Sheet — Institutional Leadership (Joint Publication with ARL)
The document provides a comprehensive briefing on the National Institutes of Health (NIH) Final Policy for Data Management and Sharing, which became effective in January 2023. This policy marks a significant expansion from previous data management requirements, mandating that all NIH-funded research projects—including those below $500,000 in annual direct costs—develop and regularly update Data Ma
