COGR has recently updated its "Framework for Navigating the 2025 Administration Transition" to include a Summary of Emerging Federal Terms and Conditions.
Other Proposal & Award Issues
Covers additional and emerging issues related to policies, regulations, and practices for the administration of federal research proposals and awards.
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COGR Joins AAMC-Led Amicus Brief Opposing Federal Stay in NIH Grant Restoration Cases
This document is an amicus curiae brief submitted by major academic and research organizations in support of respondents opposing the U.S. government’s blanket...
COGR Advocates for Full Reinstatement of NIH Grants in Joint Association Letter to Director, Dr. Bhattacharya
The letter, signed by leading higher education associations representing the majority of U.S. biomedical research institutions, urges NIH Director Dr. Jay...
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All Other Proposal & Award Issues Articles
COGR, NACUBO, and 7 Other Organizations File Amicus Brief Supporting Community Appeal of Indirect Cost Cap
This document is an amicus curiae brief filed in the First Circuit Court by COGR, the National Association of College and University Business Officers, and 7 other higher education associations in support of university plaintiffs challenging the U.S. Department of Energy’s policy imposing a uniform 15% cap on indirect cost rates for federally funded research at academic institutions. The brief arg
COGR's Response to OSTP's RFI on Accelerating the American Scientific Enterprise
COGR submitted a response to OSTP’s request for information (RFI) on “Accelerating the American Scientific Enterprise,” reaffirming its support for OSTP’s goal of enhancing national scientific competitiveness while reducing unnecessary administrative burden. Responding to a subset of questions posed in the RFI, the comments offered recommendations focused on improving the effectiveness and predict
The Administrative Burden of "Defend the Spend" - NCURA Magazine December 2025
The December 2025 NCURA Magazine article discusses the federal “Defend the Spend” initiative, which, through recent executive orders, imposes extensive new reporting and justification requirements on recipients of federal research funding. The authors argue that these mandates significantly increase administrative burden without improving oversight or efficiency, duplicating established risk-based
Updated: Considerations for a Federal Government Shutdown
COGR has prepared a list of items research institutions should consider in the event of a federal government shutdown to manage federally sponsored projects. This is not official guidance but rather an accumulation of past shutdown experiences with information and guidance that has been received to date. This list will be updated as more information is available.
COGR Joins AAMC-Led Amicus Brief Opposing Federal Stay in NIH Grant Restoration Cases
This document is an amicus curiae brief submitted by major academic and research organizations in support of respondents opposing the U.S. government’s blanket termination of NIH grants, arguing that such mass cancellations depart from long-standing, science-based funding principles vital to the nation’s research enterprise. The brief details how the abrupt, non-scientific cancellation of grants h
COGR Advocates for Full Reinstatement of NIH Grants in Joint Association Letter to Director, Dr. Bhattacharya
The letter, signed by leading higher education associations representing the majority of U.S. biomedical research institutions, urges NIH Director Dr. Jay Bhattacharya to reinstate all NIH grants terminated under directives recently found unlawful by a federal court. While some grants are being reinstated due to court orders, the associations highlight that many others, terminated under the same d
Fact Sheet: Defend the Spend
Executive Order 14222, intended to enhance efficiency and transparency and reduce costs in federally funded research, has instead imposed significant new administrative burdens and redundancies, notably through the “Defend the Spend” initiative. These new requirements force recipients to repeatedly justify pre-approved expenses, leading to payment delays, increased costs, and wasted effort, while
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 Submits Response to Health and Human Services Adoption of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
The Council on Governmental Relations (COGR), representing over 220 U.S. research universities and institutes, submitted formal comments to the U.S. Department of Health and Human Services (HHS) regarding the department’s interim final rule implementing the updated Office of Management and Budget (OMB) Uniform Guidance. COGR acknowledged the complexity of HHS’s dual-phased implementation—initial a
COGR Responds to NIH Proposed Collection of Post-Award Reporting Requirements
COGR submitted a formal response to the National Institutes of Health (NIH) regarding proposed post-award reporting requirements for Data Management and Sharing Plans within the Research Performance Progress Report (RPPR). COGR’s comments primarily focus on section C.5.c of the RPPR, offering targeted suggestions to enhance the clarity, utility, and efficiency of the data collection process. Speci
