June2011NIHRFIResponse

The document is a formal letter from the Council on Governmental Relations (COGR), an organization representing over 180 major research universities and affiliated institutes, to the A-21 Task Force of the National Science and Technology Council. Dated July 28, 2011, the letter responds to a Request for Information regarding the reduction of cost and administrative burden associated with federal cost principles for educational institutions, specifically those outlined in OMB Circular A-21. COGR highlights its members' significant role in conducting federally sponsored research and underscores the impact that federal regulations, policies, and practices have on research operations. The letter outlines that COGR has provided an executive summary of recommendations aimed at lessening regulatory burden, followed by detailed proposals and rationales, including suggested modifications to existing federal guidance. While the recommendations primarily pertain to research universities governed by A-21, COGR notes that many proposals may also benefit institutions operating under related federal cost principles. The letter concludes with COGR's appreciation for the task force's efforts and an expression of willingness to collaborate in implementing practical regulatory improvements. An attachment with further details on the recommendations is referenced.