The February 2022 Update from COGR (Council on Governmental Relations) provides an extensive overview of recent and forthcoming developments affecting research administration and compliance, particularly within higher education and academic research institutions. Central topics include heightened research security and intellectual property management, regulatory changes, evolving compliance requirements, and legislative updates impacting federally funded research.
Key issues addressed include growing concerns over the possible expansion of the Department of Energy’s Determination of Exceptional Circumstances (DEC) requirements beyond DOE, which could hinder university technology transfer and domestic manufacturing incentives. There is also coverage of strengthened export controls and renewed federal advisory councils, with particular attention on U.S.-China research collaborations and shifting enforcement approaches—evidenced by the Department of Justice’s revised “China Initiative” strategy and related high-profile academic cases. The update outlines significant legislative developments, such as the passage of the America COMPETES Act, which introduces nuanced research security provisions and enhanced foreign gift disclosures, and notes that the FY’22 National Defense Authorization Act passed without controversial research security measures.
Additionally, the report details implementation guidance for the National Security Presidential Memorandum-33 (NSPM-33), framing new disclosure and research security program requirements for institutions and noting ongoing stakeholder engagement with federal agencies such as OSTP, NSF, NIH, and DOE. Compliance and financial topics are also reviewed, including costing issues, audit outcomes, changes in procurement rebate treatments, and recent NIH notices on salary caps, safety plans, and policy updates. The update highlights upcoming meetings, collaborative efforts on standardized electronic CVs, and broader policy themes such as scientific integrity, diversity, and evolving federal support for research. Overall, the document reflects COGR's active engagement with policy makers to advocate for balanced regulations, facilitate compliance, address member concerns, and maintain the integrity and competitiveness of the U.S. academic research enterprise.
