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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COGR's November 2025 Update
The November 2025 COGR Update details the resumption of federal research operations following a prolonged government shutdown, highlights key policy initiatives...
COGR Joins Amici Curiae Brief in Support of NIH Grant Terminations Case (Nos. 25-1611, 25-1612)
This document is a brief submitted by several major higher education associations as amici curiae to the U.S. Court of Appeals for the First Circuit, supporting...
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All Proposals & Award Policies Articles
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
July 2025 Update
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’s advocacy—including legal actions and promotion of the FAIR Model—as well as significant federal a
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
COGR Comment Letter to NSF on 22-1 PAPPG
The Council on Governmental Relations (COGR), representing 190 research universities and affiliated institutions, submitted comprehensive comments to the National Science Foundation (NSF) regarding the proposed updates in the Proposal & Award Policies & Procedures Guide (PAPPG), specifically NSF 22-1. COGR’s commentary focuses on achieving greater clarity and harmonization in policy langua
