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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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, AAMC, AAU, and APLU Submit Joint Comments to NIH on Publication Cost Limits
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 impede effective dissemination, create inequities among institutions, and hinder early-career researcher
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
COGR Joins AAU and APLU Presidents in Submitting Joint Letter to Government Officials in Response to Unnecessary Disruptions to Federally Supported Research
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, and a new NIH cap on facilities and administrative cost reimbursement. The authors urge federal official
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
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
