COGR has written to Dr. Jay Bhattacharya, Director of the National Institutes of Health (NIH), seeking clarification on recent NIH policy changes that have caused...
Proposals & Award Policies
Policies, practices, and requirements for the submission of proposals and the management of awards of federally funded research.
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The Single Audit - Updates and a Potential for Efficiency Never Fully Realized
Several Single Audit related activities have occurred over the past few months including, release of the Office of Management and Budget (OMB) draft 2025 Complian
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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
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 Initiates Contact with Newly Appointed NIH Director Regarding the Partnership Between NIH and Research Institutions and Requests Clarifications on NIH Policies
COGR has written to Dr. Jay Bhattacharya, Director of the National Institutes of Health (NIH), seeking clarification on recent NIH policy changes that have caused confusion and uncertainty within the research community. COGR requests detailed guidance on issues such as research award terminations, appeals processes, funding disruptions, centralized peer review, no-cost extensions, program changes
COGR Submits Comments in Response to DOE Interim Final Rule (IFR), "Update and Relocation of the Department of Energy Technology Investment Agreement Regulations"
The Council on Governmental Relations (COGR), representing over 225 research universities and affiliated institutions, submitted comments regarding the U.S. Department of Energy’s (DOE) interim final rule updating regulations on Other Transaction (OT) agreements. COGR acknowledges DOE's efforts to expand the use of OT agreements but expresses significant concerns about the removal of provisio
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 NSF's Comment Request: NSF PAPPG (NSF 26-1)
The Council on Governmental Relations (COGR), representing over 220 U.S. research institutions, submitted detailed comments to the National Science Foundation (NSF) regarding proposed revisions to the NSF Proposal and Award Policies and Procedures Guide (PAPPG 26-1). COGR commends NSF's history of collaborative policy development but expresses concern over certain ambiguities, new compliance
COGR Submits Comment Letter in Response to Notice to Announce NIH Updated Policy Guidance for Subaward/Consortium Written Agreements (88 FR 36603)
The Council on Governmental Relations (COGR), representing over 200 research universities and affiliated institutions in the United States, submitted formal comments to the NIH concerning the recently updated policy guidance on subaward/consortium written agreements, specifically the provision requiring foreign subrecipients to provide prime recipients with all lab notebooks, data, and documentati
COGR Responds to the National Science Foundation Proposal/Award; Information— NSF Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 24-1) Comment Request
The Council on Governmental Relations (COGR), representing over 200 research universities and institutes, provided detailed feedback to the National Science Foundation (NSF) on the proposed revisions to the Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 24-1). COGR commends NSF’s efforts toward responsiveness, transparency, and stakeholder engagement, but outlines several areas
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),
