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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Cindy Hope
Director, Costing and Financial Compliance
All Other Post Award Articles
Comparing Foundation and Federal Government Research Support
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. academic research and development funding, in contrast to the federal government’s 55 percent, thei
COGR Responds to OMB's Invitation to Provide Comments and Technical Corrections to Address Select Items in the Recently Released OMB Guidance for Federal Financial Assistance (Fourth Look)
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 and subawards, urges reconsideration of changes regarding fixed amount awards, and advocates for the rea
Great Minds: Brainstorming & Benchmarking with COGR Member Institutions: June 2024
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 institutions to discuss compliance, policy implementation, and operational challenges related to research
OMB Advance Questions: June 2024 Meeting
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 both constructive feedback and concerns from institutional stakeholders about the practical implicat
COGR Joins AIRI in Submitting Comments to OMB on the Treatment of Salaries and the Executive Level II Salary Limitation
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 indirect salaries funded by institutions themselves. The organizations argue that, for the past 30 yea
COGR Responds to OMB's NPRM on Guidance for Grants & Agreements "Uniform Guidance"
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 dedication throughout the rulemaking process but highlights several areas where the proposed changes
COGR Responds to OMB's Request to Provide Data-driven Evidence to Support Modifications to 2 CFR Chapter 2, Part 200 (2 CFR 200) of the Uniform Guidance (UG)
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 research at academic institutions. Drawing on recent surveys and studies, COGR advocates for three p
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 OMB's RFI: Uniform Guidance (2 CFR 200)
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.
COGR Posts DRAFT Response to OMB (Uniform Guidance)
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 Parts 25, 170, 175, 176, 180, 182, 183, and 200). The letter outlines a series of recommendations aimed a
