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 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...
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Krystal Toups
Director, Contracts & Grants Administration
All Proposals & Award Policies Articles
Uniform Guidance Revisions—Then, Now and When October 2025
A summary from COGR's October 2025 membership meeting of updates to the Uniform Guidance (2 CFR 200) Compliance Supplement affecting research institutions’ management of federal awards, as well as potential issues in future F&A cost reimbursement models.
October 23-24, 2025 COGR Meeting Materials
Slide presentations shared during the October 23-24, 2025 COGR meeting in Washington D.C.
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
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
SAM Registration Process – Challenges & Tips : February 2024 Meeting
The COGR Virtual Meeting held February 27 to March 1, 2024, included a session focused on the System for Award Management (SAM.gov) entity registration process, presented by Ivana Henry from the U.S. General Services Administration and moderated by Krystal Toups of CGA (COGR). The presentation provided a comprehensive overview of SAM.gov, the officially managed platform for organizations aiming to
