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Addendum to COGR Response to Proposed UG – July 31, 2013

The Council on Governmental Relations (COGR), representing leading research universities, has submitted an addendum to comment on the proposed Uniform Guidance for federal grants as outlined in OMB-2013-0001. The letter acknowledges the federal initiative’s promise for meaningful grants reform, emphasizing the potential to provide regulatory relief and enhance the effectiveness and efficiency of federally funded research, especially during times of fiscal constraint. COGR expresses concern that certain counter-recommendations within the public comment process may undermine the President’s intention of reducing administrative burden and instead could lead to increased regulation.

COGR reiterates its principal priorities, which include reforms to effort reporting, subrecipient monitoring, direct charging of staff salaries for project management and compliance activities, allowability of computing devices as direct costs, simplification of cost accounting standards, flexibility in performance and financial reporting, and maintenance of rational procurement standards. The organization contends these measures would not compromise accountability or oversight but would instead streamline compliance, allowing institutions to focus resources on research excellence and stewardship. COGR warns that failure to address these key reforms risks undermining the goals of the grants reform initiative and urges federal bodies to maintain a commitment to practical, outcome-oriented regulation.

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