The document is a formal letter from the Council on Governmental Relations (COGR) to a policy analyst at the Office of Federal Financial Management, Office of Management and Budget (OMB), addressing proposed revisions to 2 CFR Chapter 2, Part 200 (Uniform Guidance) as it relates to federally funded research at academic institutions. Drawing on recent surveys and studies, COGR advocates for three principal changes: eliminating the Disclosure Statement (DS-2), recognizing fair reimbursement practices for modern research libraries, and improving the timeliness of the establishment of Facilities & Administrative (F&A) and fringe benefit cost rates.
COGR, representing over 200 major public and private U.S. research institutions, argues that the DS-2 is largely obsolete, unused by auditors and duplicative of information already available elsewhere, thereby constituting an unnecessary administrative burden. In relation to libraries, the letter emphasizes the evolving role and significant compliance responsibilities of research libraries in data management and research support, advocating for revisions to cost allocation policies to fairly reimburse these expanded functions. Finally, COGR highlights concerns regarding significant delays in the negotiation and establishment of F&A cost rates, proposing specific procedural changes and timelines to provide clarity, predictability, and reduce uncertainty for institutions. The letter underscores the importance of updating federal regulations to reflect current research practices, enhance transparency, promote administrative efficiency, and ensure equitable participation across diverse research organizations.
