The Council on Governmental Relations (COGR), representing over 150 leading research universities, provided detailed commentary on the Office of Management and Budget’s (OMB) proposed Bulletin on Peer Review and Information Quality. While COGR supports the foundational goals of objectivity, utility, quality, and integrity in federal agency information dissemination, the organization raises significant concerns regarding the breadth, prescriptiveness, and potential unintended consequences of the proposed peer review requirements. Specifically, COGR argues that the OMB’s expansive definition of “regulatory information” and the lack of clear, objective criteria could unnecessarily subject a vast array of scientific studies to duplicative and costly peer review processes, straining both agency and research community resources without clear benefit.
COGR also critiques the proposed prescriptive approach to selecting peer reviewers, which risks excluding the most knowledgeable scientists—particularly those with active federal research funding—under the premise of conflict of interest, thereby diminishing the quality of reviews. The organization further highlights the impractical burdens created by requiring additional documentation, public comment responses, and detailed reporting, which may deter expert participation and divert resources from substantive scientific evaluation. COGR ultimately recommends that OMB revise the guidance to narrow its scope, focus on outcome-based objectives rather than rigid process mandates, and minimize additional burdens and redundancies. The Council asserts that these changes would better align the guidance with both the practicalities of academic peer review and the performance-based principles increasingly favored in federal regulation.
