Policy Perspective
Financial Assistance Regulations-Conflict of Interest and Conflict of Commitment Policy Requirements
This document is a formal response jointly submitted by the Association of American Universities (AAU), the Association of Public & Land-Grant Universities (APLU), and the Council on Governmental Relations (COGR) to the U.S. Department of Energy (DOE) regarding its Notice of Proposed Rulemaking (NPRM) on Financial Assistance Regulations concerning Conflict of Interest (COI) and Conflict of Com
2023-2024 COGR Year In Review
The 2023-2024 "Year in Review" from the Council on Governmental Relations (COGR) highlights the organization's sustained commitment to advocating for effective, efficient, and harmonized federal research policies and regulations on behalf of its now 220 member institutions. Celebrating its 75th anniversary, COGR recognized both its historical roots as an advisory body within NACUBO
NCURA Article:Institutions’ Experiences with the Department of Defense Policy for Risk-Based Security Reviews of Fundamental Research: By Kristin H. West A SUMMARY OF RESULTS FROM COGR’S SURVEY OF MEMBER INSTITUTIONS
The document summarizes the experiences of U.S. research institutions with the Department of Defense’s (DoD) policy for risk-based security reviews of fundamental research, particularly in response to heightened concerns about foreign influence in academia. Following the June 2023 publication of DoD’s risk assessment policy and decision matrix, the Council on Governmental Relations (COGR) conducte
COGR Responds to Request for Comments: Biosketch and Current and Pending Support Disclosure Policy
COGR provided feedback on NASA's proposed Biosketch and Current and Pending Support Disclosure Policy, emphasizing the need for uniformity with National Science and Technology Council (NSTC) common forms to minimize administrative burden and enhance compliance. COGR urged NASA to avoid unnecessary deviations from federal standards, align definitions and reporting requirements (especially for senio
COGR Submits Comments to NIH on Intramural Research Program Policy: Promoting Equity Through Access Planning
COGR responds to the NIH’s draft policy requiring licensees of NIH technologies to submit access plans aimed at promoting patient access, expressing support for the aim of equity but cautioning that such requirements may unintentionally complicate technology commercialization and deter potential licensees due to increased risks and uncertainties. COGR recommends that NIH focus on adjusting its own
COGR Responds to NIH Proposed Collection of Post-Award Reporting Requirements
COGR submitted a formal response to the National Institutes of Health (NIH) regarding proposed post-award reporting requirements for Data Management and Sharing Plans within the Research Performance Progress Report (RPPR). COGR’s comments primarily focus on section C.5.c of the RPPR, offering targeted suggestions to enhance the clarity, utility, and efficiency of the data collection process. Speci
Overview of OSTP Guidelines for Research Security Programs at Covered Institutions
The OSTP Research Security Program Guidelines, released July 9, 2024, establish four required elements for research security compliance—cybersecurity, foreign travel security, research security training, and export control training—at institutions exceeding a $50 million annual federal R&D threshold, with detailed timetables for agency and institutional implementation. The Guidelines promote u
COGR and AAMC Submit Joint Letter to DEA on Rescheduling Marijuana
The Association of American Medical Colleges (AAMC) and the Council on Governmental Relations (COGR) submitted joint comments to the DEA in support of the proposed rescheduling of marijuana from Schedule I to Schedule III under the Controlled Substances Act, highlighting that this shift would reduce barriers and administrative burdens for cannabis research at their member institutions. They recomm
COGR Responds to OMB's Invitation to Provide Comments and Technical Corrections to Address Select Items in the Recently Released OMB Guidance for Federal Financial Assistance (Fourth Look)
This comment letter offers detailed comments and proposed technical corrections to the OMB’s updated Uniform Grant Guidance for Federal Financial Assistance, set to take effect October 1, 2024. The letter highlights COGR's recommendations on timely implementation of new thresholds for equipment and subawards, urges reconsideration of changes regarding fixed amount awards, and advocates for the rea
Great Minds: Brainstorming & Benchmarking with COGR Member Institutions: June 2024
The document outlines the agenda and discussion themes for the "Great Minds: Brainstorming & Benchmarking" session held COGR on June 6, 2024. Moderated by key COGR directors and committee chairs from prominent research institutions, the session provides a collaborative platform for member institutions to discuss compliance, policy implementation, and operational challenges related to research
