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...
Foreign Contracts & Gift Reporting
Foreign contracts and gift reporting is essential for ensuring transparency regarding foreign support of U.S. universities as required under certain federal reporting obligations.
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COGR Signs on to Multi-Association Letter to DoEd Regarding Foreign Gift & Contract Disclosures (ED-2022-SCC-0159)
The letter, submitted by the American Council on Education and a coalition of higher education associations, provides detailed comments to the U.S. Department of...
COGR Submits Comments to Dept. of Education on Section 117 Reporting
COGR, representing major research universities and affiliated institutions, submitted feedback on the Department of Education's proposed changes to foreign gift and...
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Kevin Wozniak
Director, Research Security & Intellectual Property
All Foreign Contracts & Gift Reporting Articles
COGR Responds to Request for Comments: Biosketch and Current and Pending Support Disclosure Policy
COGR provided feedback on NASA's proposed Biosketch and Current and Pending Support Disclosure Policy, emphasizing the need for uniformity with National Science and Technology Council (NSTC) common forms to minimize administrative burden and enhance compliance. COGR urged NASA to avoid unnecessary deviations from federal standards, align definitions and reporting requirements (especially for senio
NSF & Foreign Gift Reporting Requirements: June 2024 Meeting
The document outlines recent updates to the National Science Foundation’s (NSF) research security policies, with a focus on implementing a transparent and risk-based approach to safeguarding research, particularly in areas with potential national security implications, as mandated by the CHIPS and Science Act and recent appropriations reports. It details the NSF’s phased introduction of the TRUST
Research Security Updates with NSF: February 2024 Meeting
The COGR Virtual Meeting held from February 27 to March 1, 2024, featured a research security update delivered by Dr. Rebecca Keiser, Chief of Research Security Strategy & Policy at the National Science Foundation (NSF). Dr. Keiser detailed ongoing efforts to bolster research security in response to mandates from the CHIPS and Science Act of 2022. Key provisions of this legislation include pro
COGR Participates in Joint Association Response to Comment Request; Agency Information Collection Activities; Submission to OMB for Review and Approval; Foreign Gifts and Contracts Disclosures
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 acknowledging the significance of research security and transparency, as well as recent improvements s
COGR Signs on to Multi-Association Letter to DoEd Regarding Foreign Gift & Contract Disclosures (ED-2022-SCC-0159)
The letter, submitted by the American Council on Education and a coalition of higher education associations, provides detailed comments to the U.S. Department of Education regarding its proposed Information Collection Request (ICR) related to reporting foreign gifts and contracts under Section 117 of the Higher Education Act. The organizations affirm their commitment to transparency and compliance
Multi-Association Follow Up Letter to DoEd on Section 117
The letter from the American Council on Education (ACE), addressed to senior officials at the U.S. Department of Education (ED), conveys appreciation for updates regarding the management and reporting requirements of Section 117 of the Higher Education Act, which pertains to the disclosure of foreign gifts and contracts by higher education institutions. ACE acknowledges the helpfulness of the June
Outstanding Questions on Section 117
The document outlines a comprehensive list of outstanding questions and concerns from higher education institutions regarding the U.S. Department of Education’s (ED) implementation of Section 117, which mandates reporting of foreign gifts and contracts. Following the launch of a new electronic reporting portal in June 2020, stakeholders express ongoing uncertainties related to procedural updates,
COGR Joins Multi Association Letter to OSTP on NSPM-33 Implementation
The letter, authored by leading higher education associations, addresses Dr. Eric Lander, Director of the Office of Science and Technology Policy (OSTP), following a federal roundtable on implementing National Security Presidential Memorandum-33 (NSPM-33). The associations express support for safeguarding federally funded research while upholding the critical openness of the U.S. research ecosyste
COGR’s Releases Paper on “Foreign Influence—Practical Considerations in Developing an Institutional Response”
This document outlines the increasing federal scrutiny on inappropriate foreign influence in U.S. academic research and offers practical considerations for institutions to develop effective research security responses. Triggered by concerns such as undisclosed foreign funding, participation in foreign government talent programs, and intellectual property theft—especially with a focus on China—U.S.
Multi Association Letter to Department of Education on Section 117
The correspondence from the American Council on Education (ACE), co-signed by numerous higher education associations, responds to the U.S. Department of Education’s (ED) November 2020 Notification of Interpretation (NOI) concerning enforcement authority under Section 117 of the Higher Education Act (HEA). ACE emphasizes the higher education sector’s commitment to preventing illicit foreign influen
