Research Data & Access Policies
Encompasses issues related to the management, sharing, and stewardship of scientific data, including policies on public access, storage, privacy, and security.
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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...
COGR Partners in Multi-Association Comment Letter on NIH Plan to Increase Findability and Transparency of Research Results Through the Use of Metadata and Persistent Identifiers (PID)—NOT-OD-25-050
The Association of Public and Land-grant Universities (APLU), Association of Research Libraries (ARL), Association of American Universities (AAU), and COGR express...
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All Research Data & Access 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
May 2025 COGR Update
The May 2025 COGR Update provides an overview of recent federal policy changes, regulatory actions, and litigation that are significantly reshaping research administration and compliance. COGR highlights challenges posed by new indirect cost caps, increased regulatory and reporting burdens, grant terminations, and evolving agency requirements—including those related to foreign subawards, public ac
March 2025 Update
The March 2025 COGR Update provides an overview of the complex and rapidly changing federal research environment, detailing the significant impact of recent policy shifts, executive orders, and administrative actions on research institutions. It highlights escalating regulatory burdens, funding disruptions, and compliance challenges, as well as the association’s advocacy for pragmatic implementati
COGR Responds to USDOJ’s Notice of Proposed Rulemaking—Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons
COGR, representing over 220 U.S. research institutions, submitted comments on the Department of Justice’s proposed rule aimed at restricting access to U.S. sensitive personal and government-related data by countries of concern. COGR expresses concern that the rule’s lack of exemptions for non-federally funded, non-clinical research would severely hinder essential international public health and fo
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
COGR Joins a Multi-Association Response to the Request for Comments to Docket Number DoD–2023–OS–0063 / Regulatory Identifier Number (RIN) 0790–AL49, “Cybersecurity Maturity Model Certification (CMMC) Program”
The collective comments submitted by the American Council on Education (ACE), Association of American Universities (AAU), Association of Public and Land-Grant Universities (APLU), COGR, and EDUCAUSE address the Department of Defense’s proposed updates to the Cybersecurity Maturity Model Certification (CMMC) Program. The associations commend the DoD for recognizing that fundamental research general…
COGR and AAU Team to Submit Input on the Ongoing Discussion Regarding NIH's Levers to Catalyze Technology Transfer
The letter, jointly submitted by the Association of American Universities (AAU) and the Council on Governmental Relations (COGR), provides detailed input in response to an NIH workshop on technology transfer and the transformation of research discoveries into commercial products. Representing a broad consortium of leading research universities and affiliated institutions, the authors emphasize the
COGR Submits Joint Association Response to OMB on Comment Request; iEdison System
The letter, submitted by COGR and other higher education associations, expresses strong support for the continued redesign, expansion, and harmonization of the iEdison invention reporting system across all federal agencies, as outlined in OMB Control No. 0693-0090. The associations highlight the benefits of uniform reporting requirements under the Bayh-Dole Act, including reduced compliance burden
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
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),
