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
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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
NIH Latest Updates—June 2024 Meeting
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 (DMS) Plan templates based on feedback from both researchers and program officials, with particular atte
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
Session Materials Available: Workshop on Compliance with Research Security Requirements and the Associated Cost of Compliance Survey
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 members of COGR’s four committees.
Workshop on Compliance with Research Security Requirements and the Associated Cost of Compliance Survey
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 discussions focused on current and forthcoming mandates from agencies such as NSF, NIH, DOE, and DOD, emphasizi
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
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
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),
