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, 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
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 Joint Association Response for NSF Public Access 2.0
The joint letter from the Association of Public and Land-grant Universities (APLU), Association of American Universities (AAU), and the Council on Governmental Relations (COGR) provides detailed feedback on the National Science Foundation’s (NSF) Public Access Plan 2.0. The organizations commend the NSF’s engagement with the research community and its flexibility regarding publication venues and t
Laws, Policies, & Agency Guidance Concerning Research Security
Laws, Policies & Agency Guidance Concerning Research SecurityThis section provides links to statutes, regulations, and other sources of legal requirements related to science and security, links to federal research agency policy and guidance in this area. Resources are grouped in reverse chronological order (i.e., most recent resources are listed first) under t
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's NIH Data Management and Sharing Readiness Guide: Chapter 4 Part II, Project-Based and Institutional Cost Considerations - Budgeting & Costing
This document, Chapter 4 Part II of the COGR NIH DMS Readiness Guide, addresses the key budgeting and costing considerations associated with implementing the NIH Data Management and Sharing (DMS) Policy at academic and research institutions. It emphasizes the importance of carefully identifying, budgeting, and managing both direct and indirect DMS-related costs in grant applications. The guide out
COGR Review of the Final NIH Policy for Data Management and Sharing: Budgeting & Costing
The COGR Review of the Final NIH Policy for Data Management and Sharing provides a thorough analysis of the challenges institutions and researchers face regarding budgeting and costing in compliance with the new NIH policy effective January 25, 2023. The document acknowledges that while the policy aims to enhance robust data sharing and scientific advancement, it introduces significant new complia
Roles and Responsibilities: Considerations for Institutions
The document provides comprehensive guidance for institutions preparing to comply with the NIH’s Final Policy for Data Management and Sharing (DMS), effective January 2023. It emphasizes the cultural shift required to prioritize data sharing throughout the research lifecycle, aiming to enhance transparency, reproducibility, and the efficient use of taxpayer-funded research. Institutions are advise