Policy Perspective
OMB Advance Questions: June 2024 Meeting
The document presents a series of detailed, advance questions directed at the Office of Management and Budget (OMB) concerning recent changes and updates to federal grant administration guidance, particularly with respect to cost principles, indirect costs, and award management. The queries reflect both constructive feedback and concerns from institutional stakeholders about the practical implicat
A Second Look at the Final OMB Guidance for Federal Financial Assistance – Webinar Poll Results
The document presents the results of a webinar conducted on May 15, 2024, which surveyed participants on their familiarity and perspectives regarding the final OMB guidance for federal financial assistance. The poll addressed topics such as the extent of participants’ review, equipment capitalization thresholds, institutional implementation strategies, and primary office leadership, collecting res
COGR & AAU Submit Joint Comments in Response to Unlocking the Full Potential of Intellectual Property by Translating More Innovation to the Marketplace (Docket No. PTO-C-2024-004)
COGR and AAU, representing leading U.S. research universities, submitted comments to USPTO Director Kathi Vidal expressing agreement with AUTM’s positions and addressing key issues impacting university technology transfer and innovation commercialization. They voiced serious concerns about NIST's draft march-in rights framework, warning that its adoption could deter investment and harm patent lice
Results from COGR’s Survey on Research Institutions’ Experiences with DoD Policy for Risk-Based Security Reviews of Fundamental Research
The Council on Governmental Relations (COGR) surveyed 82 member institutions to assess their experiences with Department of Defense (DoD) requirements for risk-based security reviews and mitigation plans in fundamental research. The majority of respondents were public universities, with a significant portion also conducting export-controlled and classified research. Approximately half of the insti
COGR Responds to Advance Notice of Proposed Rulemaking—“Provisions Regarding Access to Americans’ Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern”
The Council on Governmental Relations (COGR), which represents over 200 U.S. research universities and affiliated institutes, submitted comments in response to the U.S. Department of Justice’s Advance Notice of Proposed Rulemaking (ANPRM) concerning restrictions on access to Americans’ sensitive personal and government-related data by countries of concern. COGR acknowledges the importance of prote
COGR Joins AIRI in Submitting Comments to OMB on the Treatment of Salaries and the Executive Level II Salary Limitation
The Council on Governmental Relations (COGR) and the Association of Independent Research Institutes (AIRI), collectively representing over 300 research institutions, formally express concerns regarding a potential policy change that would extend the Executive Level II federal salary limitation to indirect salaries funded by institutions themselves. The organizations argue that, for the past 30 yea
COGR Submits Response to CDC on Notice of Proposed Rulemaking on Possession, Use, and Transfer of Select Agents and Toxins; Biennial Review of the List of Select Agents and Toxins
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted feedback to the Centers for Disease Control and Prevention (CDC) regarding the Notice of Proposed Rulemaking on the Possession, Use, and Transfer of Select Agents and Toxins, and its biennial review of the select agents list. COGR supports the proposed removal of Br
COGR Responds to APHIS Notice of Proposed Rulemaking on Agricultural Bioterrorism Protection Act of 2002; Biennial Review and Republication of the Select Agent and Toxin List
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted comments in response to the USDA’s Animal and Plant Health Inspection Service (APHIS) Notice of Proposed Rulemaking (NPRM) regarding the biennial review and republication of the Select Agent and Toxin List under the Agricultural Bioterrorism Protection Act of 2002.
COGR Joins a Multi-Association Response to the Request for Comments to Docket Number DoD–2023–OS–0063 / Regulatory Identifier Number (RIN) 0790–AL49, “Cybersecurity Maturity Model Certification (CMMC) Program”
The collective comments submitted by the American Council on Education (ACE), Association of American Universities (AAU), Association of Public and Land-Grant Universities (APLU), COGR, and EDUCAUSE address the Department of Defense’s proposed updates to the Cybersecurity Maturity Model Certification (CMMC) Program. The associations commend the DoD for recognizing that fundamental research general…
