The COGR May 2016 Update addresses a wide range of regulatory, policy, and compliance issues relevant to research institutions, with a focus on federal grant management, procurement standards, audit requirements, and evolving legislative and regulatory landscapes. The report highlights ongoing interactions with federal agencies, such as the Department of Health and Human Services (HHS), Office of Management and Budget (OMB), and National Science Foundation (NSF), to address challenges in implementing Uniform Guidance, procurement standards, and single audits. COGR discusses deeply collaborative efforts with OMB and peer associations aiming to clarify and potentially adjust the micro-purchase threshold under procurement policies, noting pending survey results that may influence an extension of the compliance grace period and possible rulemaking changes.
Key topics include analyses of Affordable Care Act compliance for graduate students, equitable cost treatment of off-campus research centers, and the implications of newly published federal rules on contractor information security. The report reviews the status of export control definitions and the administration’s push for open source software, raising concerns about administrative burden and the commercialization impact of such policies. Drug pricing and the use of Bayh-Dole march-in rights remain contentious, with COGR monitoring related legal and policy debates. Other significant updates cover impending changes to patent legislation, subject matter eligibility guidance from the Patent and Trademark Office, and new management practices guides. Changes in overtime rules affecting research staff compensation and comprehensive analyses of proposed changes to human subjects research protections (Common Rule) are discussed, reflecting strong opposition within the research community to some of the new measures. The update also reports on structural and policy shifts at agencies such as the NIH and NSF, as well as ongoing efforts toward research regulatory reform, underscoring COGR’s commitment to advocating for clarity, equity, and reduced administrative burden across the research enterprise.
