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 reaffirmation of longstanding principles of consistency and fair share in federal research funding; it also addresses several technical points, including clarifications on voluntary uncommitted cost sharing, sole source procurement, and indirect cost rate processes. COGR urges OMB to consider these recommendations and corrections to ensure effective, equitable, and less burdensome regulatory compliance for research institutions, with an emphasis on transparency, partnership, and support for U.S. research competitiveness.