February 21, 2023

COGR Submits Comments to GSA Regarding the Transition of the Federal Audit Clearinghouse - read more...

COGR provided comments to the GSA regarding the transition of the Federal Audit Clearinghouse from the U.S. Census Bureau to the GSA.


June 30, 2022

COGR Submits Comments to OMB Regarding the 2022 Compliance Supplement - read more...


December 15, 2021


Posted December 15, 2021


August 30, 2021

COGR Submits Comments to OMB on 2 CFR 200 Subpart F - Audit Requirements Appendix XI - Compliance Supplement 2021 - read more...


May 14, 2021

COGR Writes to NSF to Address Concerns on Recent Audit Findings Related to Application of the F&A Cost Rate - read more...

Posted on May 14, 2021


May 8, 2020

Furlough Programs and Implications for Financial Research Compliance (Updated) - read more...

Posted May 8, 2020


July 26, 2019

COGR Letter to OMB on 2019 Compliance Supplement - read more...

Posted July 26, 2019


October 20, 2017

COGR Submits Letter to OMB on Payments/Reimbursements under Single Audit - read more...

*As Sent to COGR Listserv 10/20:


COGR has sent the following letter to Gilbert Tran at OMB.


Some of your institutions have been challenged in recent single audits. Specifically, a new auditor position is that prior to billing a federal sponsor for reimbursement, the institution must have evidence that the institution’s payment to the vendor has been cleared by the institution’s bank. This is in conflict with existing policy per 2 CFR Part 200.305(b): … payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.


Public Comments are due October 31, 2017. The COGR letter to OMB and Mr. Tran is attached. We encourage you to submit a letter if this issue is a concern at your institution. A letter in support of the COGR letter, with any examples specific to your institution, is appropriate.


DIRECTIONS FOR SUBMITTING LETTERS:  As specified in an August 14th Federal Register Notice, comments should be submitted to Gilbert Tran at Include “2 CFR Part 200.305, Subpart F-Audit Requirements, Appendix XI-Compliance Supplement-2017” in the subject line and the full body of your comments in the text of the email and as an attachment. Include your name, title, organization, postal address, telephone number, and email address in the text of the message. Comments may also be sent through


This is an important issue to a number of institutions and comment letters from your institution, in addition to the COGR letter, will elevate the unease around this issue. Contact David Kennedy at if you have questions on how to best craft your concerns to OMB.


March 29, 2017

COGR Submits Letter to OMB to Address 2017 Compliance Supplement and Securing Student Information - read more...

The National Association of College and University Business Officers (NACUBO), EDUCAUSE, the National Association of Student Financial Aid Administrators (NASFAA), and COGR write to OMB to address a proposed new section to the 2017 Compliance Supplement: Securing Student Information, Student Financial Aid (SFA) Cluster.

Click here.


October 21, 2014

COGR Survey and the Role of the DS-2 - read more...


January 1, 2011

Regulatory and Financial Reform of Federal Research Policy - Recommendations to the NRC

Click here to view the Recommendations.