Policy Perspective
February 13, 2015 - COGR Response to OMB on Uniform Implementation
COGR has submitted its comments to the December 19, 2014 Federal Register Notice on Federal Awarding Agency Regulatory Implementation of Office of Management and Budget's Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (2 CFR [art 200)
Official COGR Response to Final UG – February 13, 2015
The Council on Governmental Relations (COGR), representing over 190 research universities and affiliated institutions, submitted a formal response to the White House Office of Management and Budget (OMB) on February 13, 2015, regarding the implementation of Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR part 200). COGR commended the OMB and t
January 22, 2015 - COGR Letter to OHRP on Draft Guidance on Disclosing Reasonably Foreseeable Risks in Research Evaluating Standards of Care
COGR sent a letter to the Office for Human Research Protections on draft guidance concerning disclosure of reasonably foreseeable risks in research evaluating standards of care.
January 16, 2015—Joint AAU and COGR Letter to NIST on Controlled Unclassified Information
The joint letter from the Association of American Universities (AAU) and the Council on Governmental Relations (COGR) to the National Institute of Standards and Technology (NIST) addresses concerns regarding the draft NIST Special Publication 800-171, which outlines security requirements for protecting controlled unclassified information (CUI) in nonfederal organizations. The authors acknowledge N
January 16, 2015 - COGR Summary of Background and Technical Corrections to Final Uniform Guidance
The document prepared by David Kennedy and the COGR Costing Policies Committee provides a detailed overview of the background and technical corrections related to the implementation of the Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, commonly referred to as Uniform Guidance (UG). This guidance consolidated
COGR Survey and the Role of the DS-2
A 2014 survey of the COGR membership indicated that the DS-2 disclosure statement requirement did little, at best, to enhance stewardship of federal funds.
NIH Definition of Clinical Trial Case Studies
The document presents a series of 23 case studies evaluating various types of research against the NIH definition of a clinical trial, providing rationales for each determination. It illustrates that a study qualifies as a clinical trial if it involves human subjects, prospective assignment to interventions (including behavioral, biomedical, or diagnostic procedures), and the assessment of health-
COFAR – COGR Review: OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
The document provides a detailed review and set of recommendations from the Council on Governmental Relations (COGR) regarding the implementation of the Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards—commonly known as the Uniform Guidance (UG). The content outlines specific regulatory sections discussed during
Finances of Research Universities
This paper, published by COGR in June 2014, provides an in-depth analysis of the financial structure and challenges faced by research universities in the United States. It explores the evolving revenue streams and expenditures of public and private research universities, highlighting the shift from state appropriations to greater dependence on federal research funding, tuition, private gifts, and
