Policy Perspective
COGR Responds to EPA Scientific Integrity Policy Draft for Public Comment (EPA-HQ-ORD-2023-0240; FRL-10973-01-ORD)
The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted formal comments to the Environmental Protection Agency (EPA) regarding the agency's draft Scientific Integrity Policy. While COGR strongly supports the policy's overall goal of enhancing scientific integrity and promoting transparent, objective research, t
COGR, EDUCAUSE, and AAU Submit Joint Comment Letter to GSA on Cyber Threat and Incident Reporting & Information Sharing (FAR 2021-017)
EDUCAUSE, COGR, and the Association of American Universities (AAU) submitted comments expressing concern over the scope and impact of the proposed changes in Federal Acquisition Regulation Case 2021-017, which would require all federal contractors—including higher education institutions engaged in fundamental research—to comply with broad cyber incident reporting and software bill of materials (SB
Higher Education Associations Comments to NIST
A coalition of leading academic associations, including AAU, APLU, AAMC, ACE, AUTM, and COGR, submitted comments opposing the National Institute of Standards and Technology's (NIST) Draft Interagency Guidance Framework for Considering the Exercise of March-In Rights under the Bayh-Dole Act. They argue that the proposed framework introduces unnecessary ambiguity, focuses inappropriately on “reasona
COGR Submits Comments to NIST on Draft Interagency Guidance Framework for Considering the Exercise of March In Rights
COGR, representing over 200 U.S. research institutions, submitted comments urging the withdrawal of the proposed Interagency Guidance Framework for Considering the Exercise of March-In Rights under the Bayh-Dole Act. COGR argues that the Framework, particularly its consideration of product pricing as a trigger for march-in, would undermine successful technology transfer practices, deter industry p
COGR Letter to OEI HHS-OIG
The letter from Matt Owens, President of the Council on Governmental Relations (COGR), addresses the Office of Inspector General (OIG) at the U.S. Department of Health and Human Services (HHS) following a meeting on January 30, 2024, regarding the NIH Recipient Institutions’ Reporting of Monetary Donations that Support Research Survey. COGR thanks the OIG representatives for their engagement and d
COGR Joins a Multi-Association Extension Request to NIST for the RFI Regarding the Draft Interagency Guidance Framework for Considering the Exercise of March-In Rights (Docket No.: 230831-0207)
The letter, sent by major associations representing research universities and medical colleges, requests a 90-day extension to the public comment period on the National Institute of Standards and Technology's draft interagency guidance framework regarding the exercise of march-in rights under the Bayh-Dole Act. The organizations express concern that the proposed changes significantly depart from l
COGR Responds to NIH Request for Information (RFI) on Proposed Guidance to Assured Institutions on Cephalopod Care and Use (NOT-OD-23-176)
COGR submitted a response to the NIH Office of Laboratory Animal Welfare’s (OLAW) Request for Information on Proposed Guidance to Assured Institutions concerning the care and use of cephalopods in research. While COGR supports the advancement of animal welfare and recognizes the evolving scientific understanding of cephalopod care, it expresses significant concerns about the scope and basis of OLA
COGR Submits Comments to ORI on Public Health Service Policies on Research Misconduct Notice of Proposed Rulemaking
The Council on Governmental Relations (COGR), representing over 200 major U.S. research universities and affiliates, submits extensive comments regarding the Office of Research Integrity's (ORI) proposed revisions to the Public Health Service (PHS) Policies on Research Misconduct. COGR expresses significant concerns that the proposed regulations, intended to clarify and streamline the researc
COGR Responds to OMB's NPRM on Guidance for Grants & Agreements "Uniform Guidance"
The document is a formal response from the Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, to the Office of Management and Budget’s (OMB) proposed revisions to 2 CFR Chapters 1 and 2. COGR commends OMB for its transparency and dedication throughout the rulemaking process but highlights several areas where the proposed changes
COGR Responds to Request for Information (RFI) on an Update to the Current OLAW Guidance Disclaimer
COGR responded to the Office of Laboratory Animal Welfare’s (OLAW) Request for Information regarding its proposed guidance disclaimer, expressing concern that the current wording incorrectly suggests OLAW can expand regulatory requirements beyond Congressional authority. COGR recommends that OLAW revise the disclaimer to clearly state that guidance documents are recommendations, not binding requir
