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Comment Letter

COGR Submits Comments to ACURO to Review Policy for Partially DOD-Funded Animal Research

COGR expresses concerns to the U.S. Army Medical Research and Development Command's Animal Care and Use Review Office (ACURO) regarding a new policy that, effective…

Comment Letter

COGR Submits Comments in Response to DHHS RFI: Ensuring Lawful Regulation and Unleashing Innovation to Make America Healthy Again

COGR, representing over 230 U.S. research universities and affiliated institutions, submitted detailed feedback to the Department of Health and Human Services (DHHS)...

Comment Letter

COGR Joins Multi-Organization Statement on Addressing the Shortage of Long-Tailed Macaques for Research

A coalition of 40 organizations from scientific, veterinary, and conservation fields has issued recommendations to address the critical shortage of long-tailed...

Resources

Comment Letter 03 Nov, 2025

COGR Submits Comments to ACURO to Review Policy for Partially DOD-Funded Animal Research

COGR expresses concerns to the U.S. Army Medical Research and Development Command's Animal Care and Use Review Office (ACURO) regarding a new policy that, effective January 1, 2026, limits ACURO protocol review to only Department of Defense (DOD) fully-funded animal research projects. While...

Archived 29 Oct, 2025

COGR_Animal_Research_Statement

The Council on Governmental Relations (COGR), in its Animal Research Statement, underscores the critical role that animal research has played in advancing medical knowledge and treatment for both humans and animals. The document notes that nearly every significant medical advancement over the past…

COGR Update 26 Sep, 2025

COGR’s September 2025 Update

The September 2025 COGR Update provides an overview of recent federal developments affecting U.S. research institutions, including proposed regulatory changes, executive orders, litigation updates, and agency-specific policy shifts impacting research funding, compliance, security, and administration...

COGR Update 18 Jul, 2025

July 2025 Update

The July 2025 COGR Update offers a comprehensive review of recent policy, legal, and regulatory developments affecting research institutions, with primary focus on federal funding, research security, administrative burden, and the controversial 15% cap on indirect cost reimbursement. It details…

Comment Letter 14 Jul, 2025

COGR Submits Comments in Response to DHHS RFI: Ensuring Lawful Regulation and Unleashing Innovation to Make America Healthy Again

COGR, representing over 230 U.S. research universities and affiliated institutions, submitted detailed feedback to the Department of Health and Human Services (DHHS) on streamlining federal research regulations to reduce administrative burden, enhance regulatory consistency, and foster…

Comment Letter 20 Dec, 2023

COGR Responds to NIH Request for Information (RFI) on Proposed Guidance to Assured Institutions on Cephalopod Care and Use (NOT-OD-23-176)

COGR submitted a response to the NIH Office of Laboratory Animal Welfare’s (OLAW) Request for Information on Proposed Guidance to Assured Institutions concerning the care and use of cephalopods in research. While COGR supports the advancement of animal welfare and recognizes the evolving…

Comment Letter 31 Oct, 2023

COGR Responds to Request for Information (RFI) on an Update to the Current OLAW Guidance Disclaimer

COGR responded to the Office of Laboratory Animal Welfare’s (OLAW) Request for Information regarding its proposed guidance disclaimer, expressing concern that the current wording incorrectly suggests OLAW can expand regulatory requirements beyond Congressional authority. COGR recommends that…

Comment Letter 06 Oct, 2023

COGR Responds to RFI on Flexibilities for Streamlining IACUC Review of Protocols and Significant Changes (NOT-OD-23-152)

COGR submitted formal comments in response to the NIH’s Request for Information (RFI) regarding flexibilities for streamlining Institutional Animal Care and Use Committee (IACUC) review processes. COGR emphasizes the importance of maintaining animal welfare and research integrity while…

Comment Letter 01 Aug, 2023

COGR Joins Multi-Organization Statement on Addressing the Shortage of Long-Tailed Macaques for Research

A coalition of 40 organizations from scientific, veterinary, and conservation fields has issued recommendations to address the critical shortage of long-tailed macaques—a species essential for medical research and health advancements—stemming from increased demand during the COVID-19 pandemic…

Comment Letter 28 Jul, 2023

COGR Responds to OLAW's Request for Information (RFI) on Clarification of Animal Activities Exempt from PHS Policy Requirements for IACUC Review (NOT-OD-23-119)

COGR submitted comments in response to the National Institutes of Health (NIH) Office of Laboratory Animal Welfare’s (OLAW) Request for Information regarding clarification of animal activities exempt from Public Health Service (PHS) Policy requirements for Institutional Animal Care and Use…

Comment Letter 28 Apr, 2023

COGR's Response to Request for Information (RFI) on Update to NOT-OD-05-034 Guidance on Prompt Reporting of Noncompliances to OLAW (NOT-OD-23-063)

COGR submitted a letter to the National Institutes of Health’s Office of Laboratory Animal Welfare (OLAW) regarding the proposed update to guidance on prompt reporting of noncompliance in animal research. COGR acknowledges the importance of clear and unambiguous reporting standards, which…

Comment Letter 06 Mar, 2023

COGR Submits Comments in Response to ANPRM Entitled Wild and Exotic Animal Handling, Training of Personnel Involved with Public Handling of Wild and Exotic Animals, and Environmental Enrichment for Species

The Council on Governmental Relations (COGR), representing over 200 research universities and affiliated institutions, submitted comments in response to the USDA Animal and Plant Health Inspection Service's (APHIS) advance notice of proposed rulemaking concerning wild and exotic animal handling,…

Event Materials 19 Oct, 2022

Have We Reached the Proverbial Fork in the Road for Animal Research?: October 2022 Meeting

The document discusses the growing challenges and critical crossroads faced by the field of animal research in the United States, particularly as societal values increasingly prioritize animal welfare over scientific advancement. It highlights how regulatory pressures, legislative intervention, and…

Comment Letter 22 Apr, 2022

COGR Submits Comments to USDA on Proposal Rule on Standards for Birds Not Bred for Use in Research Under AWA

The document is a formal comment letter submitted by the Council on Governmental Relations (COGR), an association representing nearly 200 U.S. research universities and related institutions, to the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (USDA APHIS) concerning a…

Policy Perspective 18 Mar, 2022

Summary of USDA APHIS Proposed Rule

The USDA Animal and Plant Health Inspection Service (APHIS) has proposed a rule to amend Animal Welfare Act (AWA) regulations by introducing comprehensive standards for the care, handling, treatment, and transportation of birds not bred specifically for research. The rule, published in February…

Comment Letter 28 Oct, 2021

COGR Submits Joint Association Letter to OLAW on NOT-OD-21-161 RFI

The document is a formal submission of comments from three leading organizations—the Association of American Medical Colleges (AAMC), the Council on Governmental Relations (COGR), and the National Association for Biomedical Research (NABR)—in response to an NIH Request for Information (RFI)…

Survey 11 Feb, 2019

Animal Survey Results - COGR Survey

The document summarizes institutional responses to proposed streamlining measures for animal research oversight, particularly pertaining to Institutional Animal Care and Use Committees (IACUC). Significant support was observed for proposals aiming to reduce administrative burdens, such as expanding…

Survey 11 Feb, 2019

COGR 2018 Animal Research Survey Report Appendix A: Actions to Reduce Institutional Administrative Requirements Associated with Animal Research

The Appendix A of the COGR 2018 Animal Research Survey Report outlines a series of recommended actions aimed at reducing the administrative burden associated with institutional oversight of animal research. Key recommendations include eliminating annual protocol renewals and certain regulatory…

Policy Perspective 11 Feb, 2019

COGR Survey Report on Institutional Administrative Requirements for Animal Research

The 2018 Animal Research Survey Report by the Council on Governmental Relations (COGR) assesses the administrative requirements imposed by research institutions on animal research, with a focus on efforts to reduce unnecessary institutional burden. COGR, representing 188 major research institutions…

Comment Letter 08 Jun, 2018

COGR's Response to NIH OLAW's Request for Comments

The Council on Governmental Relations (COGR), representing prominent research universities and affiliated institutions, presents comprehensive comments in response to proposed federal actions aimed at improving coordination and harmonization of laboratory animal welfare regulations. Drawing on…

External Resource 28 Feb, 2018

Resources

NIH Initiative to Reduce Regulatory Burden (1999) Federal Demonstration Partnership Faculty Workload Survey Reports (2012) National Academies report Research Universities and the Future of America (2012) National Science Board report Reducing Investigators’ Administrative Workload for Federally...

Comment Letter 14 Nov, 2017

Joint Comment Letter on USDA Reform

The document constitutes a formal comment submitted by the Association of American Universities (AAU), the Association of Public and Land-grant Universities (APLU), and the Council on Governmental Relations (COGR) to the U.S. Department of Agriculture (USDA) in response to a federal request for…

Event Materials 14 Nov, 2017

Animal Regulatory Reform Report: October 2017 Meeting

This document is a comprehensive report resulting from an April 2017 workshop organized by leading scientific and academic organizations (FASEB, AAMC, COGR, with assistance from NABR) to address the regulatory burdens associated with animal research. Recognizing the critical role animal research…

Archived 24 Aug, 2017

Recommendations for HHS and NIH Research Regulatory Reform

The document critically examines the expanding regulatory and administrative burdens faced by U.S. academic research institutions engaged in federally funded research, particularly under the Department of Health and Human Services (HHS) and the National Institutes of Health (NIH). Despite a series…

Policy Perspective 23 Jun, 2017

Reducing Regulatory and Institutional Burden Associated with Animal Research: June 2017 Meeting

The document provides a thorough overview of ongoing efforts and recommendations to alleviate regulatory and institutional burdens associated with animal research in the United States, highlighting concerns from academic institutions, federal agencies, and advisory bodies. Key initiatives include…

Comment Letter 29 Sep, 2016

August 3, 2015 - Joint COGR/AAU Comments on the Petition to Develop Specific Ethologically Appropriate Standards for Non-Human Primates in Research

COGR and AAU submitted joint comments on the petition to develop specific ethologically appropriate standards for non-human primates in research.

Comment Letter 08 Aug, 2016

Association Responses to Petitions to the USDA

The joint letter from the Association of American Universities (AAU) and the Council on Governmental Relations (COGR) responds to a USDA request for public comment on a petition proposing amendments to the Animal Welfare Act (AWA) regulations. Specifically, the petition asks for the development of…

Comment Letter 08 Aug, 2016

Association Responses to Petitions to the USDA

The joint letter from the Association of American Universities (AAU) and the Council on Governmental Relations (COGR) responds to a USDA request for public comment on a petition proposing amendments to the Animal Welfare Act (AWA) regulations. Specifically, the petition asks for the development of…

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