The Association of American Medical Colleges, Association of American Universities, Association of Public and Land-grant Universities, and COGR submitted joint...
Financial Management & Compliance
COGR addresses financial requirements impacting research including facilities and administrative (F&A/Indirect) cost reimbursement, financial reporting, salary allocation documentation (e.g. effort reporting), financial risk management, internal controls, and audits.
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Updated: Costing Points to Consider for Terminations and Suspensions (V.2)
Communications from federal agencies about terminations and suspensions are inconsistent with each other and often with sponsor policies and Uniform Guidance.&…
Points to Consider for Reimbursement of Expenses Under Active Grants (V.2): Framework for Navigating the 2025 Administration Transition
Changes to federal payment systems, processes, and requirements implementing
Uniform Guidance Revisions—Then, Now and When October 2025
A summary from COGR's October 2025 membership meeting of updates to the Uniform Guidance (2 CFR 200) Compliance Supplement affecting research institutions’...
Facilities & Administrative (F&A/Indirect) Cost Rates Are NOT a Percent of the Total Award Infographic
The document explains that a 50% Facilities & Administrative (F&A) cost rate, which is applied only to Modified Total Direct Costs (MTDC) rather than the total award...
F&A Cost Reimbursement Materials
COGR provides this compilation of resources, many developed by COGR, explaining Facilities and Administrative (F&A/Indirect) costs, the importance of these co
Resources
Point of Contact
Cindy Hope
Director, Costing and Financial Compliance
All Financial Management & Compliance Articles
Appendix 3 to F&A Capstone Report: COGR Member Universities Responding to 2023 Cost Reimbursement Rate Survey
The document presents data from the COGR 2023 F&A (Facilities & Administrative) Survey, focusing on average administrative cost components at member universities, segmented by U.S. region and institutional research expenditures (HERD categories). The reported averages indicate notable variations across regions and institution sizes, with Northeast institutions consistently reporting some o
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.
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
May 2025 COGR Update
The May 2025 COGR Update provides an overview of recent federal policy changes, regulatory actions, and litigation that are significantly reshaping research administration and compliance. COGR highlights challenges posed by new indirect cost caps, increased regulatory and reporting burdens, grant terminations, and evolving agency requirements—including those related to foreign subawards, public ac
March 2025 Update
The March 2025 COGR Update provides an overview of the complex and rapidly changing federal research environment, detailing the significant impact of recent policy shifts, executive orders, and administrative actions on research institutions. It highlights escalating regulatory burdens, funding disruptions, and compliance challenges, as well as the association’s advocacy for pragmatic implementati
COGR February 2025 Update
The February 2025 COGR Update provides a detailed account of significant regulatory, policy, and administrative changes impacting U.S. research institutions, driven largely by executive orders from the Administration that restrict DEI programs, roll back regulations, and alter research funding and compliance practices. It highlights widespread operational disruptions, legal challenges over reduced
The 2023 COGR F&A Survey: Results & Updated Analysis: October 2023 Meeting
The 2023 COGR Facilities & Administrative (F&A) Survey, conducted between January and May 2023 with 119 institutional respondents, provides a comprehensive analysis of current F&A cost recovery practices in research institutions across the United States. The survey's findings are presented in aggregate to ensure confidentiality, serving both as a benchmarking tool for member insti
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),
Research Security and the Cost of Compliance—Phase I Report, Disclosure Requirements Now Available
COGR conducted Phase I of the survey described in this report to quantify the considerable time and resources (financial and otherwise) that research institutions have invested (or will invest) to achieve compliance with the Disclosure Requirements. COGR is providing this Phase I report to research institutions and federal research funding agencies in the hope that it will both encou
Update & Errata to COGR November 2021 Update
The document provides an update and clarification regarding the resolution of an NSF Office of Inspector General (OIG) audit finding related to the application of Facilities & Administrative (F&A) cost rates on NSF awards, as discussed during a recent NIH/NSF panel session. The concern stemmed from situations where an institution proposes an F&A cost rate during the grant application p
