Financial Management & Compliance

Several Single Audit related activities have occurred over the past few months including, release of the Office of Management and Budget (OMB) draft 2025 Compliance Supplement, a revised AICPA guide to Government Auditing Standard (GAS) and Single Audits, and new requirements dictated by Executive...

The COGR 2023 Survey of F&A Cost Rates was completed between January and May of 2023. Reports are available for download in the COGR Portal. Don't have a COGR Portal login? Request one here. F&A Cost Rates by Institution (Available for download, login required) – August 10, 2023 Institution...

On April 8, the Joint Associations Group (JAG) on Indirect Costs was announced as a community-based approach to develop new models for funding of indirect costs on federal research grants as potential replacements for the current F&A reimbursement model. On June 12 and 17, COGR will host webinars on...

(May 8 & May 12, 2025) On May 8 and 12, on behalf of the Joint Associations Group (JAG) on Indirect Costs, COGR hosted two town hall webinars. The webinars included: an overview on facilities & administrative (or indirect) costs; information about the scope, structure and work of JAG and its subject...

September 5, 2025 As leaders of the Joint Associations Group (JAG) on Indirect Costs – which represents research institutions from every state in the nation, large and small, public and private – we urge policy makers to embrace and codify the Financial Accountability in Research (FAIR) model. We...

A compilation of resources related to 2 CFR 200 "Uniform Guidance"

A compilation of resources related to the 2025 Administration Transition.

The Council on Governmental Relations (COGR) report, "Finances of Research Universities" (June 2014), presents a comprehensive analysis of the financial structure, challenges, and future outlook for U.S. research universities, drawing on data from both public and private institutions. It emphasizes…

The document, created by the Council on Governmental Relations (COGR), addresses a range of frequently asked questions concerning Facilities and Administrative (F&A) costs—often referred to as indirect costs—at research universities. These twenty questions, sourced from university faculty, are…

The document is a formal letter from the Council on Governmental Relations (COGR), representing major research universities, addressed to officials at the Office of Federal Financial Management within the Office of Management and Budget (OMB). The letter discusses the methodology for calculating…

The document provides a detailed examination of institutional costing policies and the evolution of effort reporting mechanisms, focusing particularly on the context of research universities and federally funded projects. It discusses the drawbacks of traditional effort reporting systems,…

The Council on Governmental Relations’ June 2014 executive summary, “Finances of Research Universities,” provides an analysis of the fiscal challenges facing major research institutions in the United States. The document emphasizes that both public and private research universities are confronted…

The October 24, 2025 Committee Reports & Hot Topics document from the four standing COGR Committees outlines recent and ongoing activities across its four main committees: Contracts & Grants Administration (CGA), Research Ethics & Compliance (REC), Research Security & Intellectual Property (RSIP)...

A summary from COGR's October 2025 membership meeting of updates to the Uniform Guidance (2 CFR 200) Compliance Supplement affecting research institutions’ management of federal awards, as well as potential issues in future F&A cost reimbursement models.

The document outlines the agenda and discussion framework for “Navigating the Storm 2.0: Institutional Perspectives on a Changing Federal Landscape,” a session held by COGR on October 24, 2025. The event features COGR directors leading table discussions on pressing topics such as research…

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…

The document outlines recent policy changes implemented by the Department of Energy (DOE) regarding the reimbursement of indirect costs under financial assistance awards. While the policy explicitly exempts Institutions of Higher Education (IHEs), it imposes significant limitations on indirect cost…

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 has prepared a list of items research institutions should consider in the event of a federal government shutdown to manage federally sponsored projects. This is not official guidance but rather an accumulation of past shutdown experiences with information and guidance that has been received to...

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…

Communications from federal agencies about terminations and suspensions are inconsistent with each other and often with sponsor policies and Uniform Guidance. This section provides a review of the relevant sections of Uniform Guidance and a list of items for institutions to consider when following...

The document details the agenda and key discussion points from the upcoming Costing and Financial Compliance (CFC) Committee Open House, scheduled for August 19, 2025, under the auspices of COGR. Moderated by Jeremy Forsberg and Cindy Hope, the session will focus on current challenges and evolving…

The document outlines a detailed session conducted on August 15, 2025, by the Joint Associations Group (JAG) and the Costing and Financial Compliance (CFC) Committee, focusing on the FAIR (Financial Accountability in Research) Model for research reimbursement. The agenda included a discussion on…

Changes to federal payment systems, processes, and requirements implementing Executive Order 14222 — Implementing the President's "Department of Government Efficiency" Cost Efficiency, issued February 26, 2025, have significantly increased recipient and federal burden. This section delineates COGR's...

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…

The Joint Associations Group (JAG) Virtual Town Hall on July 15, 2025, presented the Financial Accountability in Research (FAIR) Model, a proposed new framework for funding research indirect costs to enhance transparency, accountability, and simplicity across U.S. research institutions. After...

The document outlines the proposed FAIR (Financial Accountability in Research) model, designed by the Joint Associations Group on Indirect Costs (JAG) to replace the current system for indirect cost recovery (F&A costs) in federally funded research. The FAIR model aims to enhance…

The Joint Associations Group (JAG) developed the Financial Accountability in Research (FAIR) Model through extensive stakeholder engagement, including town halls, public feedback on draft models, and input from diverse research institutions and organizations. The FAIR Model aims to enhance…

The document is an amicus curiae brief filed in the United States Court of Appeals for the First Circuit by the National Association of College and University Business Officers and seventeen other higher education associations, supporting the plaintiffs-appellees—various states, academic…

Not in effect.  AAU v. DOD:  The District Court held that it had subject matter jurisdiction over the case and granted summary judgement in favor of the plaintiffs.  The District Court declared that the DOD’s Rate Cap Policy was invalid, contrary to law, and arbitrary and…

On June 12, 2025, the Joint Associations Group (JAG) on Indirect Costs held a public webinar to update the research community on its progress in developing a new funding model for the indirect costs associated with federal research grants. Comprising experts representing various research…

The Joint Associations Group (JAG) convened an informational webinar to present and discuss two provisional models (the Fiscal Accountability in Research—FAIR—Models) for funding indirect research costs in U.S. research institutions, developed by a team of subject matter experts in response to…

The document outlines the efforts of the Joint Associations Group (JAG) on Indirect Costs, comprised of leading national academic associations, independent research institutions, hospitals, and foundations, to address growing concerns regarding the current Facilities and Administrative (F&A) cost…

The document summarizes a COGR (Council on Governmental Relations) session titled "Navigating the Storm: Institutional Perspectives on a Changing Federal Landscape," held on June 6, 2025. The agenda was structured to facilitate collaborative discussions among institutional representatives on the…

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,…

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Not in effect.  AAU v. DOD:  The District Court held that it had subject matter jurisdiction over the case and granted summary judgement in favor of the plaintiffs.  The District Court declared that the DOD’s Rate Cap Policy was invalid, contrary to law, and arbitrary and…

The document presents the proceedings and content of a May 2025 virtual town hall hosted by the Joint Associations Group (JAG) on Indirect Costs, focusing on the longstanding Facilities & Administrative (F&A) cost reimbursement system in academic research. Dr. Kelvin Droegemeier led a historical…

The document pertains to a civil case before the United States District Court for the District of Massachusetts, in which several public health organizations and individuals challenge decisions by the National Institutes of Health (NIH) and the Department of Health and Human Services (HHS), along…

The Indirect Costs Subject Matter Experts (SME) Team is a distinguished group composed of leaders and experts from diverse sectors closely connected to research, academic administration, finance, government, and the private sector. Chaired by Kelvin Droegemeier, a prominent academic and former…

The document is an unopposed motion and proposed amicus curiae brief submitted to the U.S. District Court for the District of Massachusetts by major national associations representing leading academic and research institutions. These organizations—including the Association of American Medical…

National Organizations Announce Joint Effort to Develop a New Indirect Costs Funding Model April 2025 National organizations representing America’s academic, medical, and independent research institutions, along with other relevant experts(1) have come together to spur the development of a more...

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…

The document provides an in-depth exploration of Facilities & Administrative (F&A) Costs in university research, covering their historical development, purpose, and current challenges. It explains that F&A costs, often misunderstood as “overhead,” are vital reimbursements…

The document examines the potential impacts on higher education institutions of a proposed 15% Facilities & Administrative (F&A) cost reimbursement rate by NIH, featuring perspectives from university research and financial compliance leaders. Key topics include institutional responses to…

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, typically results in about one-quarter to one-third of total funding being allocated to F&A costs. This distinction…

The letter from the leaders of the AAU, APLU, and COGR expresses deep concern about recent disruptions to federally funded research resulting from executive actions and agency procedures, including interrupted payments, unclear directives relating to DEI compliance, abrupt project terminations,…

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…

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The document emphasizes the essential role of Facilities and Administrative (F&A) costs—also known as indirect costs—in supporting federally funded research in the United States. It outlines how F&A reimbursements enable research institutions to maintain necessary infrastructure, comply…

The COGR 2023 F&A Survey Capstone analyzes data from 120 research institutions to assess trends and challenges in the reimbursement of Facilities and Administrative (F&A) costs associated with federally funded research. The report finds that universities are increasingly subsidizing…

Federally sponsored research incurs both direct costs, such as researcher and student salaries, project-specific supplies, equipment, and travel, and facilities and administrative (F&A) costs, which cover essential infrastructure and support services including security, compliance,…

This document provides a comparative analysis of private foundation and federal government support for biomedical research, with a particular focus on the treatment of facilities and administrative (F&A) or indirect costs. While private foundations contribute only about 6 percent of overall U.S…

The document provides a detailed analysis of the cost structure associated with federally sponsored research at universities, explaining both the direct and indirect (facilities and administrative, or F&A) costs that comprise research budgets. It highlights the longstanding and mutually beneficial…

This document provides a comprehensive overview of Facilities and Administrative (F&A) costs—often referred to as indirect costs—associated with federally sponsored university research in the United States. F&A costs represent essential expenditures required to create and maintain the…

COGR provides this compilation of resources, many developed by COGR, explaining Facilities and Administrative (F&A/Indirect) costs, the importance of these costs to performing research, and the necessity of their reimbursement. COGR works with AAU, APLU, AAMC, ACE, NACUBO, and AIRI to update F&A...

The F&A Capstone report presents a comprehensive analysis of the 2023-2024 Facilities and Administrative (F&A) survey, focusing on the distribution of research funding, cost recovery, and compliance burdens across U.S. institutions. The survey data, drawn from a representative sample of research…

This comment letter offers detailed comments and proposed technical corrections to the OMB’s updated Uniform Grant Guidance for Federal Financial Assistance, set to take effect October 1, 2024. The letter highlights COGR's recommendations on timely implementation of new thresholds for equipment…

The document presents a series of detailed, advance questions directed at the Office of Management and Budget (OMB) concerning recent changes and updates to federal grant administration guidance, particularly with respect to cost principles, indirect costs, and award management. The queries reflect…

The document provides updates from the NIH Office of Policy for Extramural Research Administration, focusing on data management and sharing, grant closeout procedures, and research security/disclosure requirements. Key highlights include ongoing efforts to revise NIH Data Management and Sharing …

The document outlines the agenda and discussion themes for the "Great Minds: Brainstorming & Benchmarking" session held COGR on June 6, 2024. Moderated by key COGR directors and committee chairs from prominent research institutions, the session provides a collaborative platform for member…

The document presents the results of a webinar conducted on May 15, 2024, which surveyed participants on their familiarity and perspectives regarding the final OMB guidance for federal financial assistance. The poll addressed topics such as the extent of participants’ review, equipment…

The Council on Governmental Relations (COGR) and the Association of Independent Research Institutes (AIRI), collectively representing over 300 research institutions, formally express concerns regarding a potential policy change that would extend the Executive Level II federal salary limitation to…

The document is a formal response from the Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, to the Office of Management and Budget’s (OMB) proposed revisions to 2 CFR Chapters 1 and 2. COGR commends OMB for its transparency and…

The document presents a detailed examination of the increasing institutional costs and administrative burdens associated with compliance in research settings, focusing on research security requirements as driven by new federal mandates. Data from COGR surveys and institutional case studies, such as…

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…

On September 27, 2023, COGR hosted a virtual, interactive workshop to provide an opportunity for members to share information on institutional efforts to comply with research security requirements and how to assess associated costs and institutional burden. The workshop was led by COGR directors and...

The workshop, organized by the Council on Governmental Relations (COGR) and held on September 27, 2023, focused on compliance with evolving research security requirements, particularly in response to federal directives such as NSPM-33 and the 2022 CHIPS and Science Act. Key topics included the…

The workshop, held on September 27, 2023, and organized by the Council on Governmental Relations (COGR), addressed institutional compliance with evolving federal research security requirements, particularly those stemming from NSPM-33 and the 2022 CHIPS and Science Act. Presentations and…

The document is a formal letter from the Council on Governmental Relations (COGR) to a policy analyst at the Office of Federal Financial Management, Office of Management and Budget (OMB), addressing proposed revisions to 2 CFR Chapter 2, Part 200 (Uniform Guidance) as it relates to federally funded…

The letter, submitted by the American Council on Education and numerous higher education associations, provides formal feedback on the U.S. Department of Education’s (ED) proposed Information Collection Request (ICR) concerning the reporting of foreign gifts and contracts under Section 117. While…

The COGR 2023 F&A Survey provides a comprehensive overview of current practices, trends, and challenges related to Facilities and Administrative (F&A) cost rates at U.S. research institutions. Conducted between January and April 2023 with 119 respondents, the survey serves as both a benchmarking…

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…

COGR has posted its Letter to OMB, in response to OMB’s Request for Information (RFI) – Uniform Guidance. We expect OMB to review responses from all stakeholders and publish proposed revisions to the Uniform Guidance later in 2023. Contact Krystal Toups at ktoups@!zilch!cogr.edu or David Kennedy at...

The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutes, submitted a detailed response to the Office of Management and Budget’s (OMB) Request for Information regarding proposed updates to federal grant regulations (notably, 2 CFR…

The document presents a multifaceted discussion regarding the financial and regulatory challenges facing institutions of higher education (IHEs) in conducting research, with a particular emphasis on the cost burden imposed by federal requirements and the impact on American research competitiveness…

A 2014 survey of the COGR membership indicated that the DS-2 disclosure statement requirement did little, at best, to enhance stewardship of federal funds.

COGR requested a 30-day extension to respond to OMB’s RFI regarding updates to 2 CFR Part 200, Uniform Guidance.

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

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,…

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…

COGR submitted a letter to Mak Karim, the National Director for Cost Allocation Services at the U.S. Department of Health and Human Services. In the letter, COGR requests assistance to facilitate improvements in the speed of the review and approval process associated with indirect cost and fringe...

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...

The Council on Governmental Relations (COGR), representing over 200 public and private research universities and affiliated institutions, submitted formal comments to the U.S. Small Business Administration (SBA) regarding a proposed rule to revise ownership, control, and subcontracting requirements…

The document outlines institutional strategies and collaborative efforts to implement the NIH Data Management and Sharing (DMS) Policy, which became effective in January 2023. It features contributions from Duke University and the University of Delaware, alongside perspectives from key…

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.

COGR submitted formal comments in response to NASA's proposed requirement for recipients of financial assistance awards to obtain quotations from small and/or minority businesses, women's business enterprises, or labor surplus area firms for acquisitions exceeding the simplified acquisition…

The document presents a comprehensive overview of the costs and operational impacts associated with new compliance requirements related to NSPM-33, recent disclosure mandates, and the development of research security plans at research-intensive institutions. Drawing on a survey conducted among ten…

The memorandum from the Department of Veterans Affairs Office of General Counsel addresses the application of 18 U.S.C. § 209, a federal statute that generally prohibits VA employees from receiving compensation for their federal work from non-federal sources. It clarifies updated Department of…

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…

The Council on Governmental Relations (COGR), representing over 190 member institutions, submitted comments to the Office of Management and Budget (OMB) regarding the 2021 Compliance Supplement for 2 CFR Part 200, Subpart F. The correspondence, addressed to Mr. Gilbert Tran, thanks OMB for its…

Posted April 21, 2021

The document provides a detailed overview of the Higher Education Emergency Relief Fund (HEERF) as discussed in a COGR panel session on June 10, 2021, featuring perspectives from both the U.S. Department of Education and several universities. Rich Williams, representing the Department of Education,…

The document from the Office of Management and Budget (OMB), dated June 2021, provides a comprehensive overview of federal grant management, focusing on recent legislative, regulatory, and administrative changes. It traces the substantial growth in federal grant funding from 1960 to 2020 and…

The document, prepared by the Council on Governmental Relations (COGR), examines the significant challenges and emerging considerations affecting Facilities and Administrative (F&A) cost rates and reimbursements for research institutions during and after the COVID-19 pandemic. It details how the…

The document provides an audit update from the National Science Foundation’s Office of Inspector General (NSF OIG), presented by Mark Bell and Ken Lish on October 23, 2020. It outlines the structure and focus of the NSF OIG’s audit operations, mentioning key personnel and the overall federal audit…

This document offers an in-depth overview of recent developments in the landscape of Single Audits and federal oversight, particularly as they relate to institutional compliance during the COVID-19 pandemic. The presenters highlight how federal audits for fiscal years 2020 and 2021 are especially…

The Council on Governmental Relations (COGR), representing 190 member institutions, submitted a letter to Mr. Gilbert Tran of the Office of Federal Financial Management to address concerns regarding the 2020 Compliance Supplement (2 CFR Part 200, Subpart F, Appendix XI). The letter acknowledges…

The Council on Governmental Relations (COGR) submitted a letter to the Office of Management and Budget (OMB) addressing concerns regarding the implementation of prohibitions on certain telecommunications and video surveillance equipment, as outlined in revisions to 2 CFR Part 200 following Section…

This document, issued by the Council on Governmental Relations in July 2020, provides an overview of the funding sources available to research universities in the context of the profound challenges posed by the COVID-19 pandemic and the associated economic downturn. It highlights that institutions…

COGR provides a comprehensive analysis of the financial and compliance implications of implementing furlough programs at higher education and research institutions, particularly in response to the budgetary pressures brought about by the COVID-19 pandemic. It examines key considerations such as…

The Council on Governmental Relations' July 28, 2011 document presents a thorough set of recommendations to the Office of Management and Budget (OMB) aimed at alleviating administrative and regulatory burdens faced by research institutions—particularly universities, non-profit organizations, and…

The document is a formal response from the Council on Governmental Relations (COGR), an association of over 180 major research universities and affiliated institutes, to the Office of Management and Budget’s (OMB) Advanced Notice of Proposed Guidance (ANPG) regarding reforms to federal grant and…

This document, authored by the Council on Governmental Relations (COGR), provides an in-depth analysis of the funding model for federally sponsored research in the United States, with a particular focus on Facilities and Administrative (F&A) cost reimbursement. The paper outlines the historical…

The document summarizes the state of effort reporting and compensation compliance in research institutions five years after the implementation of the Uniform Guidance (UG). Presented during the October 2019 COGR meeting, the session brings together institutional representatives to discuss reform…

The document, authored by William Ferreira, Partner at Hogan Lovells, examines the legal, administrative, and strategic considerations associated with direct sponsor funding to affiliated overseas entities, as opposed to the traditional “unified” model in which such entities are integral extensions…

The Council on Governmental Relations (COGR), representing 188 member institutions, submitted feedback to the Office of Management and Budget (OMB) regarding the 2019 Compliance Supplement under 2 CFR Part 200. COGR expressed appreciation for OMB's movement toward a risk-based, performance-oriented…

The document provides a comprehensive overview of key updates and ongoing issues discussed at the Council on Governmental Relations (COGR) June 2019 meeting, focusing on costing, audit practices, and compliance for research-intensive universities. Major topics included the handling of procurement…

The Nonprofit Funder–Research Institution (NFRI) Partnership is a collaborative initiative designed to enhance and streamline the relationship between nonprofit funders and research institutions. The partnership, coordinated through regular meetings and active working groups, focuses on three core…

The document, published by the Council on Governmental Relations (COGR), provides a thorough analysis of the U.S. research funding model with a specific focus on Facilities and Administrative (F&A) cost reimbursement. COGR, comprising 190 leading research universities and institutions, outlines the…

The document “Excellence in Research: The Funding Model, F&A Reimbursement, and Why the System Works,” published by COGR, provides a comprehensive analysis of the partnership between the U.S. federal government and research institutions, focusing particularly on the importance of Facilities…

The document outlines the efforts of the NFRIRPSC (also referred to as F&A), a working group comprising leaders from major research universities and nonprofit funders, focused on improving the understanding and management of Research Project Support Costs (RPSC) and the roles of facilities and…

The document outlines foundational principles designed to foster enduring partnerships between nonprofit funders and research institutions. It emphasizes that effective collaboration should be rooted in mutual trust and align with the missions of both parties, while also being mindful of their…

The Research Project Support Costs Work Group, co-chaired by James Luther of Duke University and Heather Snyder of the Alzheimer’s Association, has undertaken a two-pronged approach to enhance understanding and management of research funding. The Education subgroup recently organized an educational…

The provided document appears to be largely composed of a mix of symbols and partially coherent text, which makes full interpretation challenging. However, it is possible to discern that the content is structured to address topics related to procedures, evaluations, and possibly instructions within…

The document outlines guiding principles designed to support long-term partnerships between nonprofit funders and research institutions. Adapted from the University Industry Demonstration Partnership Principles, these guidelines establish a framework intended to foster collaborative relationships…

The document provides an in-depth overview of the financial structure underlying federally sponsored research at U.S. universities, emphasizing the critical roles of both Direct Costs and Facilities & Administrative (F&A) Costs, often known as Indirect Costs. Direct Costs are those explicitly…

The document is an organized compendium of resource links and references related to facilities and administrative (F&A) cost rates—commonly known as indirect costs—in the context of university-based research. Spanning from recent publications in 2015 back to foundational analyses in the late 1960s,…

The OIG Panel Session at the June 2018 COGR meeting addressed key issues surrounding compensation compliance under the Uniform Guidance (UG), with a particular focus on the experiences and findings from the Federal Demonstration Partnership (FDP) Payroll Certification Pilots. High-ranking OIG…

The document provides a detailed overview of audits conducted by the Department of Health and Human Services (HHS) and the National Science Foundation (NSF) on the Federal Demonstration Partnership (FDP) Payroll Certification Systems (PCS) pilots at four universities: George Mason University (GMU),…

The provided document appears to be a lengthy, multi-part data set composed predominantly of encoded or unintelligible text, intermixed with a few recognizable words, symbols, and irregular sequences, as well as delimiters and what seem to be placeholder characters. The structure suggests that the…

The document provides an update on the activities and focus areas of the National Science Foundation (NSF) Office of Inspector General (OIG) as of February 2018, detailing changes in audit practices, ongoing and planned audits, significant findings, and outcomes of recent investigative actions. The…

The document summarizes a presentation delivered at the October 2017 COGR Meeting in Washington, D.C., focused on exploring alternatives to traditional effort reporting in research administration. Initiated by the National Council of University Research Administrators (NCURA) in January 2016, the…

The document outlines the agenda and key topics addressed by the Costing Committee at a meeting of the Council on Governmental Relations (COGR) in October 2017, comprising representatives from major research universities. The committee, led by members from institutions such as Alabama, Harvard,…

Dr. Kelvin K. Droegemeier's testimony provides a thorough historical and analytical overview of facilities and administrative (F&A) costs—also known as indirect costs or overhead—in the context of NIH-funded research at U.S. academic institutions. He explains that both direct and F&A costs are…

*As Sent to COGR Listserv 10/20: COGR has 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...

COGR joined with over 100 other organizations Monday on Director Mick Mulvaney and Health and Human Services Secretary Tom Price to oppose the proposed cuts to NIH funding and facilities and administrative (F&A) costs in the Administration's FY18 budget. Among other things, the letter states that...

The document discusses the intersection of facilities and administrative (F&A) costs with ongoing efforts to reform research regulations in the United States. It emphasizes that while research institutions and academic medical centers support reducing unnecessary federal regulations to improve the…

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…

This letter provides joint association comments on Department of Energy regulations, paperwork requirements and other regulatory obligations as part of the agency’s implementation of Executive Order 13771, “Reducing Regulation and Controlling Regulatory Costs.”

The document is a memorandum prepared by James D. Luther, Associate Vice President of Finance & Compliance Officer at Duke University, in response to requests from the House Committee on Science, Space, and Technology regarding the May 24, 2017 hearing on the overhead costs of research. The memo…

This document provides a comparative analysis of funding models and cost structures between private foundations and the federal government, specifically regarding research support for biomedical and scientific endeavors. It highlights that private foundations, while serving as essential…

The document provides an in-depth explanation of Facilities and Administrative (F&A) costs—also known as indirect costs—associated with federally sponsored research at U.S. universities. F&A costs are essential for maintaining the infrastructure and administrative support required to…

In his testimony before the House Subcommittees on Research and Technology and Oversight, James D. Luther, Associate Vice President of Finance at Duke University, discusses the critical role and financial mechanisms of the federal-university research partnership, focusing particularly on the…

Mr. James D. Luther, Associate Vice President of Finance at Duke University and Board Chair for the Council on Governmental Relations, presented an oral testimony before the House Subcommittee on Research and Technology and the Subcommittee on Oversight regarding the overhead costs—known as…

The document discusses the structure and significance of costs associated with federally funded academic research, distinguishing between direct costs—such as personnel, supplies, equipment, and travel—and facilities and administrative (F&A) costs, which encompass the operational expenses necessary…

The document addresses concerns raised by federal officials and the media regarding the proportion of National Institutes of Health (NIH) grant funding allocated to indirect, or facilities and administrative (F&A), costs—often referred to as overhead. It clarifies that both direct and indirect…

The document provides a thorough overview of Facilities and Administrative (F&A) costs, also known as research operating or indirect costs, within the context of sponsored research at universities. It outlines the distinction between direct costs—such as salaries, lab supplies, and equipment, which…

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...

The June 2014 report “Finances of Research Universities,” prepared by the Council on Governmental Relations (COGR), analyzes the evolving financial environment of research-intensive universities in the United States. The report provides a comprehensive overview of the key revenue sources and…

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The 2017 COGR Survey of Facilities & Administrative (F&A) Rates provides a detailed analysis of trends in research operating costs across U.S. research universities over a ten-year period, from FY2007 to FY2017. The survey, conducted online with input from 145 institutions, captures a…

The document outlines key changes affecting single audits under the Uniform Guidance (UG), as presented by representatives from PWC, AICPA, and KPMG. The main areas of change include adjustments to the identification of major programs, an increased emphasis on internal control procedures, and…

The Appendix B – Survey Data Sheet details the results of a 2017 survey administered by the Council on Governmental Relations, focusing on institutional practices related to federal rate agreements, clinical trials, and negotiation experiences. Of the 145 institutions responding, 70% were public…

Appendix A provides a series of survey screen shots, spanning ten sequential pages. Each page appears to capture visual representations of the user interface presented to survey respondents during the data collection process. The inclusion of these screen shots serves to document the design,…

The Council on Governmental Relations (COGR), representing 190 leading research universities and institutions conducting over $60 billion in annual research, conducted its 2017 Survey of Facilities & Administrative (F&A) Rates to analyze trends and understandings in the reimbursement of indirect…

The executive summary from the Council on Governmental Relations (COGR) provides an analysis of the financial landscape confronting research universities in the United States, highlighting both challenges and the need for collaborative solutions. The document underscores that research universities,…

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The Council on Governmental Relations (COGR), in concert with multiple higher education and nonprofit research organizations, submitted this formal letter to the Office of Management and Budget (OMB) to address concerns and propose revisions regarding the implementation of procurement standards…

COGR provides an in-depth analysis of how universities address federal requirements for effort reporting related to compensation on federally funded research awards. Triggered by recent audit findings and heightened oversight, the paper explores the relevant federal guidance—principally OMB…

COGR provides an in-depth analysis of how universities address federal requirements for effort reporting related to compensation on federally funded research awards. Triggered by recent audit findings and heightened oversight, the paper explores the relevant federal guidance—principally OMB…

COGR provides an in-depth analysis of how universities address federal requirements for effort reporting related to compensation on federally funded research awards. Triggered by recent audit findings and heightened oversight, the paper explores the relevant federal guidance—principally OMB…

COGR provides an in-depth analysis of how universities address federal requirements for effort reporting related to compensation on federally funded research awards. Triggered by recent audit findings and heightened oversight, the paper explores the relevant federal guidance—principally OMB…

to view the full document. to view the Executive Overview.

to view the full document. to view the Executive Overview.

to view the paper.

“Finances of Research Universities” describes the financial landscape of research universities and calls for active collaboration among all stakeholders to address financial risks to the research enterprise in a productive manner.

“Finances of Research Universities” describes the financial landscape of research universities and calls for active collaboration among all stakeholders to address financial risks to the research enterprise in a productive manner.

to view

to view the Policy Paper to view the Appendix

to view the Policy Paper to view the Appendix

The document, authored by David Kennedy and submitted to the National Research Council Committee on Research Universities in January 2011 by the Council on Governmental Relations (COGR), Association of American Universities (AAU), and Association of Public and Land-grant Universities (APLU),…

to view the Policy Paper.

Input on Reduction of Cost and Burden Associated with Federal Cost Principles for Educational Institutions (OMB Circular A-21), July 2011. to view the Letter and to view the Attachment.

Input on Reduction of Cost and Burden Associated with Federal Cost Principles for Educational Institutions (OMB Circular A-21), July 2011. to view the Letter and to view the Attachment.

Discontinuation of the Effort Reporting Requirement, November 2011. for the proposal.

OMB Advance Notice of Proposed Guidance, April 2012. for the letter.

for the Guide.

for the Guide. If interested in a Word version of the Guide, please contact David Kennedy.