Data Management & Public Access
Covers policies, practices, and requirements governing data management and sharing, as well as compliance with federal public access policies for scientific data.
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COGR, AAMC, AAU, and APLU Submit Joint Comments to NIH on Publication Cost Limits
The Association of American Medical Colleges, Association of American Universities, Association of Public and Land-grant Universities, and COGR submitted joint...
The Single Audit - Updates and a Potential for Efficiency Never Fully Realized
Several Single Audit related activities have occurred over the past few months including, release of the Office of Management and Budget (OMB) draft 2025 Complian
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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, AAMC, AAU, and APLU Submit Joint Comments to NIH on Publication Cost Limits
The Association of American Medical Colleges, Association of American Universities, Association of Public and Land-grant Universities, and COGR submitted joint feedback to the NIH opposing proposed limitations on allowable publishing costs for NIH-funded research, arguing that such limits could impede effective dissemination, create inequities among institutions, and hinder early-career researcher
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 COGR’s advocacy—including legal actions and promotion of the FAIR Model—as well as significant federal a
COGR Responds to Centers for Medicare & Medicaid Services February 2024 Request for Information on Research Data Request and Access Policy Changes – Updated March 1, 2024
COGR submitted comments in response to the Centers for Medicare & Medicaid Services’ (CMS) proposed policy changes concerning access to Research Identifiable Files (RIF Data). COGR emphasizes that the proposed mandate to confine research using CMS data to the CMS Chronic Conditions Warehouse Virtual Research Data Center (CCW VRDC) would significantly impede the ability of researchers to link d
COGR Submits Comment Letter in Response to Notice to Announce NIH Updated Policy Guidance for Subaward/Consortium Written Agreements (88 FR 36603)
The Council on Governmental Relations (COGR), representing over 200 research universities and affiliated institutions in the United States, submitted formal comments to the NIH concerning the recently updated policy guidance on subaward/consortium written agreements, specifically the provision requiring foreign subrecipients to provide prime recipients with all lab notebooks, data, and documentati
Cost of Compliance: Results from the COGR Survey on the Cost of Complying with the New NIH DMS Policy
The document summarizes the findings from a 2022 COGR survey assessing the financial and administrative burdens imposed by the new NIH Data Management and Sharing (DMS) Policy, effective January 2023, which expanded data management requirements to all NIH-funded research projects generating scientific data. The survey, completed by 34 institutions (29 mid-size to large and 5 smaller institutions),
COGR Responds to the NIH Plan to Enhance Public Access to the Results of NIH-Supported Research [NOT-OD-23-091]
This document is a formal response from the Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, to the National Institutes of Health’s Request for Information regarding its plan to enhance public access to the results of NIH-supported research. COGR expresses support for the OSTP directive that increases access to federally funded
COGR Submits Letter to NIH on Genomic Data Sharing Policy RFI (NOT-OD-22-029)
The Council on Governmental Relations (COGR), representing 200 U.S. research universities and affiliated institutions, submitted comments to the National Institutes of Health (NIH) on proposed updates and long-term considerations for the NIH Genomic Data Sharing (GDS) Policy. COGR commends NIH’s efforts to solicit public input on balancing the imperative of data sharing—essential for scientific pr
Joint Association Letter to OSTP on Public Access RFI
The document is a memorandum from key academic associations responding to the Office of Science and Technology Policy’s (OSTP) request for input on increasing public access to scholarly publications, data, and code from federally funded research. It emphasizes broad support for OSTP’s aims, highlighting the benefits of accelerated scientific inquiry and research integrity that arise from open acce
COGR Submits Letter to OSTP on “Draft Desirable Characteristics of Repositories for Managing and Sharing Data Resulting from Federally Funded Research
The Council on Governmental Relations (COGR), representing a consortium of 188 research universities, medical centers, and research institutes, submitted feedback to the Office of Science and Technology Policy (OSTP) regarding draft guidelines for desirable characteristics of data repositories managing federally funded research data. COGR acknowledges the value of accessible, well-managed data rep
