Executive Order 14222, intended to enhance efficiency and transparency and reduce costs in federally funded research, has instead imposed significant new...
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Financial research accounting, management, and billing activities are subject to various and evolving requirements. COGR assesses and reports on significant changes, as well as advocating for practical requirements that provide effective safeguards without undue administrative burden.
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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
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.&…
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All Other Post Award 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
Frequently Asked Questions (FAQs) on JAG Effort and FAIR Model
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 transparency and accountability by establishing clear, trackable cost categories, aligning project costs with actua
COGR, NACUBO, and 16 Other Organizations File Amicus Brief Supporting Community Appeal of Indirect Cost Reimbursement Rate Cap
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 institutions, and medical associations—against the National Institutes of Health (NIH) and the U.S. Department
DOD ONR Indirect Cost Memo
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 capricious.
COGR Joins Second Amicus Brief on HHS/NIH Grant Terminations Suit
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 with their respective leadership. The dispute centers on the abrupt termination and slowdown of a rang
COGR Joins Amicus Brief on HHS/NIH Grant Terminations Suit
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 Colleges, the American Council on Education, and others—seek leave to file a brief supporting the plaintif
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),
Dept of Veterans Affairs Memorandum: Guidance Regarding the Without Compensation and State Treasury Exceptions
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 Justice guidance and focuses on cases where VA research employees seek payment directly from non-federal
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
Multi Association Letter to House and Senate Leaders on Research Relief
The letter to Congressional leaders urges the inclusion of $26 billion in supplemental funding for federal science agencies in the next pandemic relief package. The authors, representing major higher education and research associations, emphasize that COVID-19 has severely disrupted federally funded research, particularly harming early-career researchers, and existing relief funds do not cover the
