Disclosures

Update Now Available (V.4): COGR Matrix of Science & Security Laws, Regulations, and Policies - read more...

COGR Letter to OEI HHS-OIG - read more...

COGR Comments & Extension Request to Office of Evaluation and Inspections, OIG, HHS on NIH Monetary Donations that Support Research Survey (OEI-03-22-00570) - read more...

COGR, APLU, and AAU Submit Joint Response to Request for Public Comment on Common Disclosure Forms for the Biographical Sketch and Current and Pending (Other) Support for Use in Submission of Research Applications - read more...

COGR Publishes "Analyzing Personal Financial and Institutional Conflicts of Interest in Academic Research Contexts" - read more...

COGR has published a new report:  “Analyzing Personal Financial and Institutional Conflicts of Interest in Academic Research Contexts.”  Ensuring the objective conduct of research, free from bias, is one of a research institution’s most important duties, as well as a key focus for federal research funding agencies.  This report discusses both personal financial and institutional conflict of interest issues in the context of situations in which these conflicts most commonly occur, including consulting, licensing, and clinical studies.  The report also addresses federal research funding agencies’ recent focus on the intersection of conflicts and malign foreign influence, and includes key regulations and guidance documents, points institutions should consider in evaluating scenarios, and case studies that can be used to foster discussion and support educational efforts. 

“Analyzing Personal Financial and Institutional Conflicts of Interest in Academic Research Contexts” complements COGR’s 2021 publication:  "Principles for Conflict of Commitment Concerns in Academic Research." 

Research Security and the Cost of Compliance – Phase I Report, Disclosure Requirements Now Available - read more...

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 institutions and federal research funding agencies in the hope that it will both encourage and facilitate discussions of equitable cost allocation, as well as how “return on investment” (ROI) should be considered and measured.

Joint Comments from AAU, AAMC, APLU, ACE and COGR to NSF on Standard Disclosures - read more...

COGR Letter for Request for Comment for Common Disclosure Forms - read more...

NSPM-33 Implementation Guidance Disclosure Requirements Standardization Talking Points for Institutions - read more...

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 COGR response. 

Comparison Chart: NIH Pre-Award and Post-Award Disclosures Relating to the Biographical Sketch and Other Support - read more...

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.

Summary of NSTC Guidance for Implementing National Security Presidential Memorandum 33: Provisions Regarding DPIs, Consequences, Information Sharing and Research Security Programs - read more...

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.

COGR Releases a Summary of NSTC Guidance for Implementing NSPM-33's Disclosure Requirements & Other Provisions - read more...

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. 

Framework for Review of Individual Global Engagements in Academic Research - read more...

This paper provides research institutions with an underlying structure to support the analysis of international engagements by their researchers, assess potential risks, and develop strategies for mitigation.

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Principles for Evaluating Conflict of Commitment Concerns in Academic Research (Update) - read more...

Updated September 22, 2021

This paper examines the issue of conflict of commitment in the context of concerns regarding inappropriate foreign influence, promoting transparency, and avoiding conflicts. 

Joint Association Comments on NIST NPRM Proposed Changes to Part 401 and 404 - read more...

Posted April 5, 2021

This letter provides association comments regarding changes proposed to Part 401 Rights to Inventions Made by Nonprofit Organizations and Small Business Firms Under Government Grants Contracts and Cooperative Agreements.

COGR’s Survey on Institutional Disclosure Practices: Responding to Inappropriate Foreign Influence Amid Evolving Requirements

COGR’s Survey on Institutional Disclosure Practices: Responding to Inappropriate Foreign Influence Amid Evolving Requirements (Log in required)

Released December 2020

This paper provides analysis of the data collected via COGR's survey on institutional disclosure requirements regarding research support and researcher affiiliations.  It is availble only to COGR members. 

COGR Releases Current and Pending Support Table (NSF) - read more...

Posted 9/22/20

Conflict of Commitment Policies for COGR Member Institutions - read more...

Posted November 19, 2019

COGR Releases Commentary on Disclosing Other Support - read more...

Posted December 5, 2019

COGR Comments on DOI Conflict of Interest Policy - read more...

Posted April 8, 2016

COGR Seeks Clarification from the U.S. Fish & Wildlife Service on COI Language - read more...

Posted February 11, 2016

COGR Submits Letter to DOD on COI Requirements - read more...

Posted November 9, 2015