The Council on Governmental Relations (COGR), representing 190 major research universities and institutes, submits a detailed response to the Office of Management and Budget’s (OMB) proposed revisions to 2 CFR Parts 25, 170, 183, and particularly Part 200, which governs federal awards. COGR commends OMB’s efforts to improve clarity and reduce compliance burdens but emphasizes that many university leaders were constrained in their ability to collaborate on these comments due to the COVID-19 crisis. The document offers targeted feedback on numerous sections, recognizing positive changes such as clearer procurement guidance, the inclusion of more flexible indirect cost policies, specified responsibilities for pass-through entities in audit findings, and improvements in closeout procedures. COGR supports the move toward codifying select Frequently Asked Questions (FAQs) into the regulations to reduce ambiguity and administrative overhead and recommends ensuring clear, consistent terminology throughout, particularly with regard to procurement and performance periods.
Despite positive developments, COGR raises concerns about several proposed changes, cautioning that new requirements—such as those making grant agreements resemble procurement contracts or introducing more restrictive cost-timing—could elevate administrative burdens and negatively affect research flexibility. The organization critically addresses the need for transparency without exposing institutions to misinterpretation and requests that federal requirements like the Utility Cost Adjustment (UCA) methodology be updated using more accurate data. COGR also objects to proposals that would allow arbitrary award termination or restrict cost charging across budget periods, seeing such moves as potentially disruptive. The letter closes by urging OMB to maintain regular dialogue with the research community, ensure any changes are accompanied by appropriate explanatory materials, and remain open to ongoing refinements that strike a balance between reducing administrative costs and ensuring accountability. Ultimately, COGR advocates for continued partnership to achieve efficient federal program delivery while protecting the research enterprise’s integrity and productivity.
