The document is an official letter from the Council on Governmental Relations (COGR), an association representing 190 U.S. research universities and affiliated research centers, addressed to the General Services Administration regarding a proposed federal regulation known as FAR Case 2014-025 "Fair Pay and Safe Workplaces." The letter, signed by COGR President Anthony DeCrappeo and listing the organization’s Board of Directors, thanks the agency for its attention to compliance burdens faced by federally funded institutions and offers specific policy feedback. COGR emphasizes that universities often lack the expertise and resources to independently evaluate labor law compliance among their subcontractors at multiple tiers.
To address these challenges, COGR supports an alternative proposal—in Section IV.B of the referenced rule—that would have subcontractors report labor law violations directly to the Department of Labor (DOL), which would then provide determinations and guidance to university contractors. The organization argues that this approach would not only reduce administrative burden on research universities but also foster greater consistency and informed decision-making in the compliance process. COGR strongly recommends the adoption of this alternative in the final version of the regulation, while noting that flexibility for contractors to choose their evaluation method should remain. The letter concludes by expressing appreciation for the opportunity to provide input on the rulemaking process.
