Policy Perspective
COGR Joins Community Letter to NIH Requesting a Meeting to Discuss the Future Implementation of U.S. Government Policy for Oversight of DURC and PEPP
The letter, dated March 24, 2025, is a formal communication addressed to Dr. Matthew Memoli, Acting Director of the National Institutes of Health (NIH), from the leadership of the American Society for Microbiology (ASM), the Association for Biosafety and Biosecurity International (ABSA), and the Council on Governmental Relations (COGR). The organizations collectively express concerns regarding the
COGR Partners in Multi-Association Response Regarding FAR Case 2017-016, “Federal Acquisition Regulation: Controlled Unclassified Information” (Proposed Rule)
The joint comments submitted by major higher education associations—including the American Council on Education (ACE), Association of American Universities (AAU), Association of Public and Land-grant Universities (APLU), COGR, and EDUCAUSE—critique and provide recommendations on the Federal Acquisition Regulation (FAR) Case 2017-016, which introduces regulations governing Controlled Unclassified I
COGR Submits Comments in Response to NSF NITRD NCO’s “RFI—Development of an Artificial Intelligence Action Plan”
The Council on Governmental Relations (COGR) submitted comments in response to the National Science Foundation’s Request for Information concerning the development of a national Artificial Intelligence (AI) Action Plan, as mandated by Executive Order 14179. Representing over 225 research universities and affiliated institutions, COGR emphasized the importance of empowering U.S. academic research o
COGR Submits Comments in Response to DOE Interim Final Rule (IFR), "Update and Relocation of the Department of Energy Technology Investment Agreement Regulations"
The Council on Governmental Relations (COGR), representing over 225 research universities and affiliated institutions, submitted comments regarding the U.S. Department of Energy’s (DOE) interim final rule updating regulations on Other Transaction (OT) agreements. COGR acknowledges DOE's efforts to expand the use of OT agreements but expresses significant concerns about the removal of provisio
Explain Facilities & Administrative Costs. You Have Thirty Seconds: February 2025 Meeting
The document provides an in-depth exploration of Facilities & Administrative (F&A) Costs in university research, covering their historical development, purpose, and current challenges. It explains that F&A costs, often misunderstood as “overhead,” are vital reimbursements compensating institutions for necessary infrastructure and compliance expenses associated with federally funded res
Considering the Potential NIH 15% F&A Cost Reimbursement Rate and Its Institutional Impacts: February 2025 Meeting
The document examines the potential impacts on higher education institutions of a proposed 15% Facilities & Administrative (F&A) cost reimbursement rate by NIH, featuring perspectives from university research and financial compliance leaders. Key topics include institutional responses to anticipated reductions in F&A cost recovery, such as adjustments in funding decisions, budget plann
Facilities & Administrative (F&A/Indirect) Cost Rates Are NOT a Percent of the Total Award Infographic
The document explains that a 50% Facilities & Administrative (F&A) cost rate, which is applied only to Modified Total Direct Costs (MTDC) rather than the total award, typically results in about one-quarter to one-third of total funding being allocated to F&A costs. This distinction is crucial for understanding that F&A rates are not calculated from the full award amount but only fr
COGR Responds to NSF RFC on Proposed Intellectual Property Options
COGR submitted a response to the National Science Foundation’s (NSF) request for comments regarding proposed new intellectual property (IP) frameworks for public-private partnerships, expressing concern that prescribed, inflexible IP terms could hinder successful technology transfer and commercialization of federally funded research. COGR argued that current practices, which allow for the negotiat
COGR Joins AAU and APLU Presidents in Submitting Joint Letter to Government Officials in Response to Unnecessary Disruptions to Federally Supported Research
The letter from the leaders of the AAU, APLU, and COGR expresses deep concern about recent disruptions to federally funded research resulting from executive actions and agency procedures, including interrupted payments, unclear directives relating to DEI compliance, abrupt project terminations, and a new NIH cap on facilities and administrative cost reimbursement. The authors urge federal official
