Other Research Compliance

The document outlines the agenda and discussion framework for “Navigating the Storm 2.0: Institutional Perspectives on a Changing Federal Landscape,” a session held by COGR on October 24, 2025. The event features COGR directors leading table discussions on pressing topics such as research…

The document, presented by Dr. Courtney Karmelita, addresses the responsible use of AI in research, dispelling common misconceptions by emphasizing that AI is a valuable tool—akin to prior technological advances—that can be utilized ethically and effectively within existing frameworks and…

COGR's Summary Tracker of Executive Orders issued in the current Administration.

The July 2025 COGR Update offers a comprehensive review of recent policy, legal, and regulatory developments affecting research institutions, with primary focus on federal funding, research security, administrative burden, and the controversial 15% cap on indirect cost reimbursement. It details…

COGR tracks litigation regarding current and pending litigation related to the Administration's activities.

The Council on Governmental Relations (COGR), representing over 225 major U.S. research institutions, submitted comments in response to the Office of Personnel Management’s (OPM) proposed rule aimed at improving performance, accountability, and responsiveness in the civil service. COGR's remarks…

The letter, dated March 24, 2025, is a formal communication addressed to Dr. Matthew Memoli, Acting Director of the National Institutes of Health (NIH), from the leadership of the American Society for Microbiology (ASM), the Association for Biosafety and Biosecurity International (ABSA), and the…

The letter, addressed to Director Manjit Misra of the National Institute of Food and Agriculture at the USDA, expresses concerns from leading academic and research organizations regarding the USDA's October 8, 2024 announcement on research access to germplasm developed with federal funds. The…

COGR, representing over 220 U.S. research institutions, submitted comments to the National Telecommunications and Information Administration (NTIA) regarding the development of ethical guidelines for research using pervasive data. COGR underscores the complexity of the existing regulatory…

The document summarizes the experiences of U.S. research institutions with the Department of Defense’s (DoD) policy for risk-based security reviews of fundamental research, particularly in response to heightened concerns about foreign influence in academia. Following the June 2023 publication of…

COGR provided feedback on NASA's proposed Biosketch and Current and Pending Support Disclosure Policy, emphasizing the need for uniformity with National Science and Technology Council (NSTC) common forms to minimize administrative burden and enhance compliance. COGR urged NASA to avoid…

The OSTP Research Security Program Guidelines, released July 9, 2024, establish four required elements for research security compliance—cybersecurity, foreign travel security, research security training, and export control training—at institutions exceeding a $50 million annual federal R&D…

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…

The document outlines recent updates to the National Science Foundation’s (NSF) research security policies, with a focus on implementing a transparent and risk-based approach to safeguarding research, particularly in areas with potential national security implications, as mandated by the CHIPS…

The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted feedback to the Centers for Disease Control and Prevention (CDC) regarding the Notice of Proposed Rulemaking on the Possession, Use, and Transfer of Select Agents…

The letter from Matt Owens, President of the Council on Governmental Relations (COGR), addresses the Office of Inspector General (OIG) at the U.S. Department of Health and Human Services (HHS) following a meeting on January 30, 2024, regarding the NIH Recipient Institutions’ Reporting of Monetary…

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...

The document presents a detailed overview of current and forthcoming federal research security requirements as they pertain to federally funded research activities and institutions. It summarizes both federal-wide mandates and agency-specific implementations regarding disclosure of biographical and...

In July 2023, the Department of Defense (DOD) released a suite of materials establishing new requirements and processes to identify and mitigate risks associated with unwanted foreign influence, conflicts of interest, and conflicts of commitment in DOD-funded fundamental research at higher…

The letter, submitted by the American Council on Education and a coalition of higher education associations, provides detailed comments to the U.S. Department of Education regarding its proposed Information Collection Request (ICR) related to reporting foreign gifts and contracts under Section 117…

COGR conducted Phase I of the survey described in this report to quantify the considerable time and resources (financial and otherwise) that research institutions have invested (or will invest) to achieve compliance with the Disclosure Requirements. COGR is providing this Phase I report to research...

The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, submitted detailed comments to the National Science Foundation regarding proposed common disclosure forms for Biographical Sketch and Current and Pending (Other) Support. COGR…

The proposed Standardized Disclosure Forms were released for public comment on August 31, 2022. This document includes critical themes for institutions to consider. These themes were included in the .

The proposed Standardized Disclosure Forms were released for public comment on August 31, 2022. This document includes critical themes for institutions to consider. These themes were included in the .

The document “Digging Into DPIs,” presented by a team from the University of Arizona and the Council on Governmental Relations (COGR), offers a thorough exploration of Digital Persistent Identifiers (DPIs), also known as Persistent Identifiers (PIDs), and their growing significance in the research…

COGR has developed a comprehensive chart that summarizes and compares federal laws, regulations, and policies in the area of science and security.

The Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated medical centers, submitted detailed feedback to the Office for Human Research Protections (OHRP) regarding the July 2022 draft guidance on the use of a Single Institutional Review Board …

The CHIPS and Science Act of 2022 is expected to have a major impact on numerous facets of the U.S. science and technology landscape, including manufacturing, support of innovation, STEM education, promotion of more inclusive and diverse research and research settings, along with additional efforts...

This document compares the June 2022 version of the NIH Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Other Support with the prior version of the chart related by NIH.

The Council on Governmental Relations (COGR), representing nearly 200 U.S. research universities and related institutions, provided formal feedback in response to the NIH’s Request for Information on its Draft Strategic Plan for Scientific Workforce Diversity for 2022-2026. COGR commended NIH’s…

This paper provides an overview of points that institutions should consider on issues related to research security as they perform risk assessments and develop/implement processes to appropriately address areas of higher research security risk

The Research Ethics & Compliance Committee (REC) of the Council on Governmental Relations (COGR) serves a critical role in addressing a broad array of topics relevant to research compliance and ethics within academic institutions. Chaired by Naomi Schrag of Columbia University and composed of…

The Council on Governmental Relations (COGR), representing 200 U.S. research universities and affiliated institutions, submitted comments to the National Institutes of Health (NIH) on proposed updates and long-term considerations for the NIH Genomic Data Sharing (GDS) Policy. COGR commends NIH’s…

This letter contains COGR’s comments regarding the Implementation Guidance for National Security Presidential Memorandum 33, and stresses the need for transparency, a risk-based approach, and cross-agency consistency.

These are slides from COGR's webinar providing an overview of OSTP's NSPM-33 Implementation Guidance.

This summary highlights key points of the NSPM-33 Guidance that address the other topics covered by the document: DPIs, consequences, information sharing, and research security programs.

This summary highlights key points of the NSPM-33 Guidance’s disclosure requirements, including comparison of those provisions with current NIH and NSF requirements in this area.

The NSTC Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33) Disclosure Requirements, Version 2.0 (January 11, 2022), outlines uniform protocols and standards for disclosure requirements mandated for U.S. Government-supported research and development activities. The…

This letter provides comments regarding to NSF concerning its Privacy Act notice of a new system of records that describes the use of a data analytics tool to analyze information collected from researcher disclosures. Posted December 8, 2021

The document provides an extensive overview of the evolving frameworks, institutional responses, and ongoing challenges universities face in managing global research engagements amid increasing federal scrutiny of research integrity and disclosure compliance, especially regarding foreign…

The document "Materials Transfer in Academia: 20 Questions and Answers" (2021), published by the Council on Governmental Relations (COGR), provides a detailed overview of the complexities and best practices associated with materials transfer agreements (MTAs) within academic research. It outlines…

COGR submitted comprehensive comments to the White House Office of Science and Technology Policy (OSTP) regarding the American Research Environment. COGR commended OSTP for its cross-agency efforts to address persistent challenges in research administration, emphasizing that the proliferation of…

The "Framework for Review of Individual Global Engagements in Academic Research," developed by the Council on Governmental Relations (COGR), serves as a guidance tool for academic institutions to systematically assess and manage the risks associated with international research collaborations…

COGR, representing major research universities and affiliated institutions, submitted feedback on the Department of Education's proposed changes to foreign gift and contract disclosure requirements. While supporting the goals of transparency and avoiding undue foreign influence, COGR expresses…

Posted October 3, 2019

This letter expresses joint association concerns regarding the continuing need for clarification regarding reporting requirements under Sec. 117 of the Higher Education Act of 1965.

The presentation to the Council on Governmental Relations (COGR) provided an update from the Research Business Models (RBM) Working Group, focusing on efforts to address federal administrative and regulatory burdens on research in compliance with Section 201 of the American Innovation and…

The document, presented by Rebecca L. Keiser, Head of the Office of International Science and Engineering at the National Science Foundation (NSF), outlines the objectives, criteria, budgetary context, and key programs associated with NSF’s international research engagement. International…

The Association of American Universities (AAU) and the Council on Governmental Relations (COGR) provided a detailed response to the National Institutes of Health (NIH) regarding the use and recognition of interim research products, particularly preprints, within life sciences research. They…

This document is a formal letter from four leading professional organizations—AICPA, COGR, NACUBO, and NASACT—addressed to the U.S. Office of Management and Budget (OMB) in response to the U.S. Department of Education’s (ED) recent policy requiring a separate annual compliance audit for Title IV…

COGR signed on to a comment letter to the FAA on its proposed rule for the Operation and Certiification of Small Unmanned Aircraft System.

Reports from the National Academies, National Science Board, Federal Demonstration Partnership and others have highlighted increasing regulatory burden for federally funded research. Many of the recommendations for reducing burden target federal regulations and policies. Part 1 of the National...

The document, authored by David Kennedy and submitted to the National Research Council Committee on Research Universities in January 2011 by the Council on Governmental Relations (COGR), Association of American Universities (AAU), and Association of Public and Land-grant Universities (APLU),…