Latest News

COGR Submits Response to Interim Final Rule - "Implementation of Controls on Advanced Technologies Consistent with Controls Implemented by International Partners"

COGR's Emerging Research Institutions Pilot Program

October Meeting Materials

COGR Endorses AUECO Letter to U.S. Department of State on International Traffic in Arms Regulations: Revisions to Definition and Controls Related to Defense Services

COGR's September 2024 Update

Now Available: Fifth Look: Implementation and Readiness Guide for the OMB Guidance for Federal Financial Assistance

COGR Joins a Multi-Association Request to DOE's RTES for Full Engagement with the Research Community Prior to Implementation of Risk Matrices

COGR Joins a Multi-Association Response to NIH's Draft Public Access Policy

Updated: COGR Matrix of Science & Security Laws, Regulations, and Policies

COGR Responds to Request for Comments: Biosketch and Current and Pending Support Disclosure Policy

COGR Submits Comments to NIH on Intramural Research Program Policy: Promoting Equity Through Access Planning

COGR's July 2024 Update

COGR Responds to OMB's Invitation to Provide Comments and Technical Corrections to Address Select Items in the Recently Released OMB Guidance for Federal Financial Assistance

June 2024 COGR Meeting: Slide Presentations

Slides & Recording Now Available (Log In Required): A Second Look at the Final OMB Guidance for Federal Financial Assistance

COGR & AAU Submit Joint Comments in Response to Unlocking the Full Potential of Intellectual Property by Translating More Innovation to the Marketplace (Docket No. PTO-C-2024-004)

Results from COGR’s Survey on Research Institutions’ Experiences with DoD Policy for Risk-Based Security Reviews of Fundamental Research

COGR Position Announcement: Director for Costing and Financial Compliance

COGR Joins AIRI in Submitting Comments to OMB on the Treatment of Salaries and the Executive Level II Salary Limitation

COGR Submits Response to CDC on Notice of Proposed Rulemaking on Possession, Use, and Transfer of Select Agents and Toxins; Biennial Review of the List of Select Agents and Toxins

COGR Virtual Meeting Materials

COGR Responds to EPA Scientific Integrity Policy Draft for Public Comment (EPA-HQ-ORD-2023-0240; FRL-10973-01-ORD)

COGR's February 2024 Update

COGR's Questionnaire on HHS-OIG Survey (Please complete by 2/23)

COGR Submits Comments to NIST on Draft Interagency Guidance Framework for Considering the Exercise of March In Rights

2024 Call for Nominations - COGR Board of Directors

COGR Position Announcement: Director for Research Security and Intellectual Property

COGR Responds to NIH Request for Information (RFI) on Proposed Guidance to Assured Institutions on Cephalopod Care and Use (NOT-OD-23-176)

COGR is Moving! Update Your Institutional Records by January 1, 2024!

COGR Joins C4IP in Urging the Biden Administration to Oppose the Proposed WTO IP Waiver for Covid-19 Therapeutics and Diagnostics

COGR Submits Joint Association Request for Extension of Comment Period for Oct. 6, 2023, NPRM on PHS Policies on Research Misconduct (88 FR 69583)

COGR Responds to RFI on Potential Changes to the Policies for Oversight of Dual Use Research of Concern (DURC) and the Potential Pandemic Pathogen Care and Oversight (P3CO) Policy Framework

COGR Responds to RFI on Flexibilities for Streamlining IACUC Review of Protocols and Significant Changes (NOT-OD-23-152)

Session Materials Available: Workshop on Compliance with Research Security Requirements and the Associated Cost of Compliance Survey

On September 27, 2023, COGR is hosted a virtual, interactive workshop to provide an opportunity for members to share information on institutional efforts to comply with research security requirements and how to assess associated costs and institutional burden.  The workshop was led by COGR directors and members of COGR’s four committees.

NSTC is expected to finalize its model disclosure forms and research security program standards this autumn, and upon their issuance, COGR will initiate Phase II of its research security cost survey.  This workshop provided a forum for institutions to discuss their compliance strategies, learn about the methodology of the Phase II survey, and consider the resources they will need to implement research security programs and additional disclosure requirements.  The workshop begins with an overview of current requirements and the Phase II survey, and then participants joined break-out rooms to discuss how their institutions are addressing certification mandates, training requirements, security program structures and associated costs and administrative burden. 

Institutions that participated in the Workshop will be highly encouraged to complete the Phase II Survey.  Phase II will be initiated later this autumn, and COGR will follow-up with workshop participants at the time to determine if they will participate.  

Questions and topics of interest may be sent in advance of the session to Kristin West at kwest@cogr.edu.

Workshop materials include:

Session recording (log in required)
Slide Presentation
Institutional Resources on Research Security (log in required)

COGR's September 2023 Update

COGR's October 26-27, 2023 Meeting Preliminary Agenda Now Available

COGR Submits Response to Congressional RFI on Federal Regulation of CBD Products

COGR's 2022-2023 Year In Review

COGR Analysis on Executive Order 14104 “Federal Research and Development in Support of Domestic Manufacturing and U.S. Jobs”

COGR and AAU Team to Submit Input on the Ongoing Discussion Regarding NIH's Levers to Catalyze Technology Transfer

COGR Responds to OMB's Request to Provide Data-driven Evidence to Support Modifications to 2 CFR Chapter 2, Part 200 (2 CFR 200) of the Uniform Guidance (UG)

Overview of Department of Defense Statement on Countering Unwanted Foreign Influence in Department-Funded Research Institutions of Higher Education

COGR Submits Comment Letter in Response to Notice to Announce NIH Updated Policy Guidance for Subaward/Consortium Written Agreements (88 FR 36603)

COGR Responds to NSF's Request for Response to Dear Colleague Letter: Development of the U.S. Research Security and Integrity Information Sharing Analysis Organization

COGR Responds to the National Science Foundation Proposal/Award; Information— NSF Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 24-1) Comment Request

COGR Participates in Joint Association Response to Comment Request; Agency Information Collection Activities; Submission to OMB for Review and Approval; Foreign Gifts and Contracts Disclosures

COGR's May 2023 Update

Preliminary Agenda Now Available: COGR's June 8-9, 2023 Meeting

COGR Is Now On LinkedIn

COGR Responds to the NIH Plan to Enhance Public Access to the Results of NIH-Supported Research [NOT-OD-23-091]

Registration Now Open: COGR's June 8-9, 2023 Meeting in Washington D.C.

COGR Publishes "Analyzing Personal Financial and Institutional Conflicts of Interest in Academic Research Contexts"

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." 

COGR Responds to OMB's RFI: Uniform Guidance (2 CFR 200)

COGR has posted its Letter to OMB, in response to OMB’s Request for Information (RFI) – Uniform Guidance. We expect OMB to review responses from all stakeholders and publish proposed revisions to the Uniform Guidance later in 2023. Contact Krystal Toups at ktoups@cogr.edu or David Kennedy at dkennedy@cogr.edu if you have comments or questions

COGR's Joint Response to NASA’s “New Conflict of Interest and Conflict of Commitment Policy for Recipients of NASA Financial Assistance Awards”

Now Available: February 28-March 3, 2023 COGR Virtual Meeting Presentations & Session Recordings

COGR Signs on to Multi-Association Letter to DoEd Regarding Foreign Gift & Contract Disclosures (ED-2022-SCC-0159)

COGR Requests a 30-Day Extension to Respond to OMB's RFI

COGR requested a 30-day extension to respond to OMB’s RFI regarding updates to 2 CFR Part 200, Uniform Guidance.

COGR's February 2023 Update

COGR Responds to HHS Notice of Proposed Rulemaking “Confidentiality of Substance Abuse Disorder Patient Records”

NIH Data Management and Sharing (DMS) Policy Readiness Webinar on January 17

The final countdown approaches for the January 25, 2023, implementation of the NIH Data Management and Sharing (DMS) Policy. On January 17, COGR hosted Michelle Bulls, Director, Office of Policy for Extramural Research Administration (OPERA), NIH, to discuss the new policy as the community prepares. This webinar covered updates from NIH, presented budgeting issues recently released in Chapter 4 Part I of the COGR NIH DMS Readiness Guide, and other topics of interest. 

PowerPoint Presentation

Webinar Recording (log in required)

For additional information and resources on the NIH Data Management and Sharing Policy, please visit COGR’s Resource Page and the COGR NIH DMS Readiness Guide, including the recently released Chapter 4 Part I:  COGR Review of the Final NIH Policy for Data Management and Sharing:  Budgeting and Costing. 

COGR Announces Matt Owens as Incoming COGR President

COGR Submits Letter to HHS on Timely Establishment of Indirect Cost and Fringe Benefit Rate Agreements

COGR submitted a letter to Mak Karim, the National Director for Cost Allocation Services at the U.S. Department of Health and Human Services. In the letter, COGR requests assistance to facilitate improvements in the speed of the review and approval process associated with indirect cost and fringe benefit rates.

COGR's November 2022 Update

NOVEMBER 2022 Update Topics:

NIH Data Management and Sharing Policy: Cross Cutting Issues

     NIH Data Management and Sharing (UPDATE)

     NIH Data Management & Sharing Panel: Thursday Session at October COGR Meeting (NEW)

     Cost Impact: NIH Data Management & Sharing Policy Survey (UPDATE)

Science & Security: Cross Cutting Issues

     Research Security & Cost of Compliance: REPORT IS AVAILABLE (NEW)

     NSPM-33 and CHIPS & Science Act Research Security Provisions (UPDATES)

     NSPM-33 Implementation Guidance Disclosure Requirements & Standardization Forms: Thursday Session at October COGR Meeting (NEW)

     COGR Submits Comments to NSF on Common Disclosure Forms (NEW)

     COGR Joins Higher Ed. Association Letter to NSF on Standard Disclosure Forms (NEW)

     COGR 9/23 Webinar “Digging into DPIs” (UPDATE)

     COGR Presentation to National Academies (UPDATE)

     SBIR/STTR “Foreign Risk Management” Provisions (NEW)

     NASEM Report on Protecting Critical Technologies for National Security in an Era of Openness and Competition (NEW)

Research Security & Intellectual Property (RSIP)

     RSIP COGR Committee Holds Informal Discussion with DOD (NEW)    

     New Export Control Rules on End Users and Semiconductors (NEW)

     March-In Calls Continue (UPDATE)

Research Ethics & Compliance (REC)

     Request for Information (RFI) Regarding Cannabis Research (UPDATE)

     Responsible and Ethical Conduct of Research Changes (NEW)

     Animal Research (UPDATE)

     Human Subjects Research Certificates of Confidentiality (NEW)

     Recent FDA Guidance Document on Expanded Access (NEW)

     OSTP RFI: Clinical Research Infrastructure and Emergency Clinical Trials (NEW)

     ORI RFI Regarding Research Misconduct Regulations (UPDATE)

     OSTP Webinar on Open Access Policy (NEW)

     Conflict of Interest (COI) Publication (UPDATE)

Costing & Financial Compliance (CFC)

     F&A Cost Rate Negotiations and Engagement with Cost Allocation Services (ONGOING)

     COGR F&A Cost Rate Survey, Revisited (NEW)

     Cost of Compliance Studies: Science & Security and Data Management & Sharing (ONGOING)

     Costing & Financial Compliance: Other Issues (NEW & ONGOING)

Contracts & Grants Administration (CGA)

     NSF Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 23-1)

     Grant & Contract Administration: Other Issues (UPDATES)

COGR Submits Comments to the Small Business Administration in Response to Federal Register Notice

Joint Comments from AAU, AAMC, APLU, ACE and COGR to NSF on Standard Disclosures

COGR and ARIO Joint Response to ORI RFI Research Misconduct Policies

COGR October 2022 Meeting Materials

COGR & the Association of Research Libraries Present: Gearing Up for January 2023: Institutional Strategies for Implementing the NIH Data Management & Sharing Policy

Overview of the NSPM-33 Standardization Disclosure Forms for the Common Biographical Sketch and Current and Pending (Other) Support 9/23 Webinar Materials

The highly anticipated Standardize Disclosure Forms were released on August 31, 2022 for public comment. Section 4(b)(vi) of NSPM-33 directs that “agencies should standardize forms for initial disclosures as well as annual updates…and should provide clear instructions to accompany these forms and to minimize any associated administrative burden”. This webinar provides an overview of the standardized disclosure forms and associated attributes highlighting key considerations for institutions.

Speakers for this webinar are Pamela Webb, Associate Vice President for Research, University of Minnesota; Jeffrey Friedland, Associate Vice President, Research Administration; University of Delaware; Craig Reynolds Assistant Vice President for Research - Sponsored Projects University of Michigan; and Krystal Toups, Director, Contracts & Grants Administration. This webinar provides information on how institutions can engage and provide comments by October 31, 2022. 

COGR Matrix of Laws, Regulations, and Policies Regarding Science & Security

COGR has developed a comprehensive chart that summarizes and compares federal laws, regulations, and policies in the area of science and security.  The chart is divided into three separate tabs that cover (a) major federal-wide legislation or policy (e.g., National Presidential Security Memorandum 33, CHIPS and Science Act of 2022); (b) agency disclosure requirements for researchers and research institutions; and (c) agency conflict of interest policies.  The chart will be updated as new laws, policy and guidance are published. 

Register for COGR's October 20-21, 2022 Meeting in Washington D.C.

Multi-Association Follow Up Letter to DoEd on Section 117

This letter provides comments from the American Council on Education, Association of American Universities, Association of Public and Land-grant Universities, and COGR expressing concerns regarding Dept. of Education requirements under Sec. 117 of the Higher Education Act of 1965. 

Digging Into DPIs Webinar - Registration Open (Rescheduled to 9/23)

Technology Transfer in U.S. Research Universities: Dispelling Common Myths (Updated August 2022)

COGR Submits March-In Letter to HHS Secretary Becerra on Prescription Drug Pricing

COGR Submits Comments to OMB Regarding the 2022 Compliance Supplement

COGR Submits Comments in Response to NIH Guide Notice NOT-OD-22-131 Regarding Protecting Privacy When Sharing Human Research Participant Data

COGR May 2022 Update

COGR Submits Comments to NASA on T&C's Affecting Procurement

COGR Submits Comment Letter to NIH on NOT-OD-22-064

COGR Joins Over 90 Associations on Free and Open Academic Inquiry Statement

COGR February 2022 Update

Overview of DARPA’s Countering Foreign Influence Program (CFIP) and Senior/Key Personnel Foreign Influence Risk Rubric

Overview of DARPA’s Countering Foreign Influence Program (CFIP) and Senior/Key Personnel Foreign Influence Risk Rubric DARPA officials Wes Bennett, Director, Contracts Management Office and Kevin Flaherty, Assist. Director, Policy & Oversight, Security & Intelligence Directorate will provide an overview of DARPA’s CFIP. Their presentation will include a discussion of DARPA’s recently revised risk rubric and how the rubric will be used in the grant process. The presentation will include time for questions and answers. 

Presentation Slides

COGR Submits Letter to OSTP on Reducing Administrative Burden

This letter provides specific suggestions to OSTP for achieving its objective of reducing administrative burden associated with federally funded research, including suggestions regarding research security requirements.  

Posted December 21, 2021

COGR Submits Comment Letter to NSF in Response to "Notice of a New System of Records: (SORN)

This letter provides comments regarding to NSF concerning its Privacy Act notice of a new system of records that describes the use of a data analytics tool to analyze information collected from researcher disclosures. 

Posted December 8, 2021

COGR Submits Comments to DoEd on HEERF Data Collection Form Federal Register Notice

Posted November 8, 2021

COGR Signs On to Joint Association Letter to WH & CDC on Upcoming Changes to US Travel Policy for International Travelers and Vaccination Requirements

A Tutorial on Technology Transfer in U.S. Colleges and Universities (Updated October 2021)

Released October 1, 2021

Task Force Announces Details of Federal Contractor Vaccine Mandate (Hogan Lovells)

COGR's August 2021 Update

COGR Submits Comments to OMB on 2 CFR 200 Subpart F - Audit Requirements Appendix XI - Compliance Supplement 2021

COGR's Releases Paper on "Foreign Influence - Practical Considerations in Developing an Institutional Response"

COGR Submits Letter to DoEd in Response on HEERF I, II, & III, Data Collection Form

Posted August 12, 2021

COGR Submits Joint Association Comments with AAU, AAMC, AAAS, and APLU to OSTP on Scientific Integrity RFI

Posted July 27, 2021

COGR, AAU, and APLU Submit Letter to DOE on Order 142.3B

Posted July 12, 2021

This letter sets forth comments to the Dept. of Energy from COGR, Association of American Universities (AAU), and Association of Public and Land-grant Universities (APLU) regarding the application of DOE Order 142.3B and the removal of the  limited screening exemption for U.S. universities

COGR Joins Coalition Statement in Support of Research Using Human Fetal Tissue

COGR's May 2021 Update

F&A Cost Rates and Reimbursement Pressures Under COVID-19: Maintaining a Fair and Reliable System

Posted April 21, 2021

Joint Association Comments on NIST NPRM Proposed Changes to Part 401 and 404

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 Joins Multi Association Letter to DHS in Support of International Students Returning to Campus

Principles for Evaluating Conflict of Commitment Concerns in Academic Research

COGR Joins Coalition Letter to HHS on Proposed Fetal Tissue Rule (RIN 0991-AC15)

COGR Comment Letter to NSF on 22-1 PAPPG

COGR Joins Multi Coalition Letter to President-elect Biden on Human Fetal Tissue Research

Posted January 7, 2021

Multi Association Letter to Department of Education on Section 117

Joint Association Letter to DoD Regarding CMMC (DFARS Case 2019-D041)

COGR October 2020 Meeting Report

COGR Submits Letter to USDA APHIS on Proposed Rule Regarding AWA Research Facility Registration, Updates, Reviews, and Reports

Posted November 13, 2020

COGR Submits Comments to NIH on NOT-OD-20-153 RFI Regarding Grant and Congruency Reviews

Posted October 30, 2020

COGR Releases Uniform Guidance Readiness Guide 2020

COGR Sends Letter to OMB on the 2020 Compliance Supplement

COGR Submits Multi-Association Letter to OMB Requesting Extension/Reinstatement of M-20-17 & -26

COGR Releases Current and Pending Support Table (NSF)

Posted 9/22/20

COGR September 2020 Update

COGR Joins Coalition Letter to DHHS on the NIH Human Fetal Tissue Ethics Advisory Board

Posted August 31, 2020

COGR Submits Comments to NIH in Response to NOT-OD-20-130 RFI on Enhancing Rigor, Transparency, and Translatability to Improve Biomedical Research Involving Animal Models

Posted August 19, 2020

COGR Joins Coalition Letter to NIH Human Fetal Tissue Ethics Advisory Board

Posted July 28, 2020

June 10-12 Virtual Meeting Report

COGR Submits Comments to ORI on Sequestration RFI

COGR, AAU, APLU and AAMC Submit Letter to OMB Requesting Flexibilities in M-20-17 Be Extended

COGR Submits Letter to DEA in Regard to Federal Register Notice, "Controls to Enhance the Cultivation of Marihuana for Research in the United States

Furlough Programs and Implications for Financial Research Compliance (Updated)

Posted May 8, 2020

COGR's COVID-19 Research Impact Study

COGR has launched our COVID-19 Research Impact Study. This baseline survey (linked below) is estimated to take about 10 minutes to complete. It will be followed by brief "pulse questions" every two weeks.  The information we collect will help our members, sponsors, and other constituents to track the pandemic's effects over time.

Questions focus on your institution's research program status and staff; all responses will be reported in aggregate and de-identified.

We would like to receive only one response per institution.  To simplify the process, we ask that this survey (and subsequent pulse questions) be directed to the person in your institution who can best answer them, and/or coordinate with others in the institution to collect the information requested.

We would like to receive all responses to this baseline survey by  May 15, 2020.

If you are the best contact, please click here to enter the survey. If there is a more appropriate contact than you, please simply forward this email to that person.

Thank you in advance for your time and thoughtful insights.  If you have any questions about this survey, please email COVID19@cogr.edu.

COGR FAQs on COVID 19 Impact on Federal Awards V.2.2

Joint Association Letter to EPA to Request an Extension for the Strengthening Transparency in Regulatory Science NPRM

COGR Submits Letter to OMB on Uniform Guidance Revisions

Multi Association Request for Expanded Administrative Relief Due to the Impacts of COVID-19

COGR Submits Joint Letter to NLM on RFI for Clinical Trials.gov Modernization

COGR Submits Joint Letter with AAU to NIH on Clinicaltrials.gov Modernization

COGR Signs on To Joint Association Letter to FAA on Unmanned Aircraft Systems NPRM

COGR Joins Association Letter to Department of Education on Free Inquiry

COGR February 27-28, 2020 Meeting Agenda Released

COGR's Response to JCORE RFI

Posted January 27, 2020

This letter contains COGR's comments in response to the request for information on aspects of the American Research Environment [FR Doc. 2019-25604]

COGR Letter to NIFA Regarding the Reimagining NIFA Initiative

Posted January 23, 2020

COGR Comments to NIH on Draft Data Sharing and Management Policy

COGR Letter to SAMHSA on New Attestation Requirements

COGR Releases Commentary on Disclosing Other Support

Posted December 5, 2019

COGR October 24-25th Meeting Report Now Available!

COGR Submits Comments to Dept. of Education on Section 117 Reporting

COGR October 24-25th Meeting Agenda Now Available!

Joint Association Letter to NASA on Sexual Harassment Federal Register Notice

Posted 8/16/19

COGR Submits Comments to NSF on PAPPG

Posted 7/29/19

COGR Submits Letter to FDA on Cannabis Research

Posted 7/16/19

Association Response to DoEd on Section 117 Reporting

Posted 7/12/19

This letter expresses joint association concerns regarding the continuing need for clarification regarding reporting requirements under Sec. 117 of the Higher Education Act of 1965. 

COGR, Other Associations and Universities Support Securing American Science and Technology Act

COGR May 2019 Update

Registration Now Open for COGR's June 6-7, 2019 Meeting!

COGR Releases "Excellence in Research: The Funding Model, F&A Reimbursement, and Why the System Works"

Posted April 12, 2019

Additional F&A Resources

COGR Comments on the Draft Federal Report Reducing Administrative Burden for Researchers: Animal Care and Use in Research

Posted February 20, 2019

COGR Sends Letter to OMB on Data Standards

Posted January 15, 2019

Joint Association Comment Letter on Emerging Technologies ANPRM

Click here to view

This letter contains joint association comments in response to the Advance Notice of Proposed Rulemaking Regarding Review of Controls for Certain Emerging Technologies Reference: 83 Fed. Reg. 58201 (Nov. 19, 2018).

COGR's February 2019 Meeting Registration Now Open!

Joint Association Letter to OSP-NIH: RFI on Proposed Provisions for a Draft Data Management and Sharing Policy

Posted December 10, 2018

COGR October 2018 Meeting Report

Joint Response to NIH Registration and Results Reporting Standards for Prospective Basic Science Studies Involving Human Subjects (NOT-OD-18-217)

Posted November 13, 2018

October 2018 COGR Update

COGR Submission to DOT on NABR Complaint

Posted September 20, 2018

COGR's September 2018 Update

Statement of Support for Kelvin Droegemeier As OSTP Director

Engage Research Institutions on Research Regulatory Reform

Science, July 20, 2018

Summary

Reprint

Full Text

June 2018 COGR Meeting Report

COGR's Response to NIH OLAW's Request for Comments

COGR Final Meeting June Meeting Agenda

Joint Association Comments on the Common Rule NPRM

Posted May 16, 2018

Joint Association Letter to NSF on Reporting of Sexual Harassment (No. 144)

COGR Working Group Develops FAQs on Cannabis Research

Posted May 1, 2018

Register Today for June 7-8, 2018 COGR Meeting!!

Joint Statement on Foreign Plots Targeting America's Research and Development

COGR Comments on the Common Rule Interim Final Rule

Posted March 16, 2018

COGR February 2018 Update Now Available

COGR Releases Matrix of Recent Legislative Actions Taken to Reduce Research Regulatory Burden

Posted January 2018

COGR December 2017 Update Now Available

COGR October 2017 Meeting Report Now Available

COGR Submits Joint Association Letter to EPA Regarding Advisory Boards & Committees

Posted November 6, 2017

COGR Submits Letter to OMB on Payments/Reimbursements under Single Audit

*As Sent to COGR Listserv 10/20:

COGR has sent the following letter to Gilbert Tran at OMB.

Some of your institutions have been challenged in recent single audits. Specifically, a new auditor position is that prior to billing a federal sponsor for reimbursement, the institution must have evidence that the institution’s payment to the vendor has been cleared by the institution’s bank. This is in conflict with existing policy per 2 CFR Part 200.305(b): … payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.

Public Comments are due October 31, 2017. The COGR letter to OMB and Mr. Tran is attached. We encourage you to submit a letter if this issue is a concern at your institution. A letter in support of the COGR letter, with any examples specific to your institution, is appropriate.

DIRECTIONS FOR SUBMITTING LETTERS:  As specified in an August 14th Federal Register Notice, comments should be submitted to Gilbert Tran at hai_m._tran@omb.eop.gov. Include “2 CFR Part 200.305, Subpart F-Audit Requirements, Appendix XI-Compliance Supplement-2017” in the subject line and the full body of your comments in the text of the email and as an attachment. Include your name, title, organization, postal address, telephone number, and email address in the text of the message. Comments may also be sent through regulations.gov.

This is an important issue to a number of institutions and comment letters from your institution, in addition to the COGR letter, will elevate the unease around this issue. Contact David Kennedy at dkennedy@cogr.edu if you have questions on how to best craft your concerns to OMB.

COGR October 2017 Meeting Agenda (Updated)

The October Meeting Agenda has been slightly updated for Thursday afternoon.

Joint Association Letter on NIH Clinical Trial Case Studies

A number of institutions have contacted COGR over the last several weeks to express concern about clinical trial case studies that NIH has posted to their website to provide guidance on determining whether proposed research meets NIH criteria for a clinical trial. Many in the research community have been surprised to find that several of the case studies suggest that some basic health-related research meets the clinical trial definition.  COGR, AAMC, AAU and APLU have communicated these concerns to NIH officials.  The associations also sent a letter to Mike Lauer, NIH Deputy Director for Extramural Research, yesterday afternoon detailing our concerns and requesting continued dialogue. NIH made revisions to the case studies on September 8 and has indicated that the case studies and related guidance may continue to evolve. We will keep the membership informed of any further developments. 

Read Joint Association Letter

*Sent to COGR Listserv 9/19/17

COGR September 2017 Update Now Available

Register Today for COGR's October 26-27, 2017 Meeting

COGR Submits Joint Letter with AAU to DOD on DFARS Streamlining Measures

COGR Submits Joint Association Letter on DOE Regulatory Reform

Posted July 14, 2017

This letter provides joint association comments on Department of Energy regulations, paperwork requirements and other regulatory obligations as part of the agency’s implementation of Executive Order 13771, “Reducing Regulation and Controlling Regulatory Costs.” 

COGR Submits Joint Association Letter to Request Delay in Common Rule Compliance Date

Posted June 21, 2017

COGR May 2017 Update Now Available

COGR June 8-9, 2017 Meeting Agenda Now Available

Joint Association Request to OMB on the Research Policy Board

Posted April 27, 2017

At OMB Request: Letter to Identify OMB Actions to Reduce Administrative Burden

Posted April 17, 2017

COGR Submits Letter to DOD Regarding Pre/Post Award Administrative Matters on Financial Assistance Awards

Posted April 5, 2017

COGR Submits Comments/Questions to NIH on "Single IRB Policy FAQs for Extramural Community"

COGR submits comments and questions to NIH on the document 'NIH Single IRB Policy FAQs for Extramural Community."  Comments are indicated in red italic text.

Click here.

Call for COGR Board Nominations 2017!

COGR February 2017 Update Now Available

Overview of the Final Revised Common Rule

February 1, 2017:  An overview of the changes to the revised Common Rule published in the Federal Register on January 19, 2017, a one page summary table of the changes made, and a link to the final revised Common Rule.

Summary of Changes Made to the Common Rule

COGR Common Rule Summary Table

Final Revised Common Rule

COGR, AAU, APLU Submit Joint Comments to NIH RFI on Data Sharing NOT-OD-17-015

Click here to view

COGR Submits Letter to DOD on Proposal Submission Deadlines

Click here to view

Transition Letter to Trump Administration

COGR Supports Cures Legislation in Letter to Senate HELP Staff

Click here for letter

COGR October 2016 Meeting Report Now Available

COGR October 2016 Update Now Available

COGR 2016 Meeting Agenda Now Available!

COGR's September 2016 Update

COGR Submits Proposed FAQs on Uniform Guidance to OMB

COGR Comments on Proposed Changes to HHS Adoption of UG

June 2016 Meeting Report and Summary Now Available

COGR Submits Comments to NIH on Postdocs Supported by NRSA and RGA Awards

May 2016 Update Now Available

COGR Submits Recommendations to ORI Director Dr. Kathryn Partin

COGR and AAU Submit Joint Comments on OMB's Draft Open Source Policy

NSF Approved Notice of Preliminary IRB Approval for a Project Lacking Immediate Plans for Involvement of Human Subjects

COGR has recently engaged in conversations with Jean Feldman, Head, Policy Office, and Jeff Mantz, Human Subjects Research Protection Officer, National Science Foundation, regarding applications and proposals lacking definite plans for involvement of human subjects. Per 45 CFR 690.118, applications lacking definite plans, such as “projects in which human subjects’ involvement will depend upon completion of instruments, prior animal studies, or purification of compounds,” need not be reviewed by an IRB before an award is made. NSF has indicated that for studies that meet these criteria, IRBs may use a “Preliminary Approval” notice for NSF projects (see "Read More" below) and that this approval is consistent with the Proposal and Award Policies and Procedures Guide.

The letter was drafted by Cindy Shindledecker and Lois Brako of the University of Michigan who have been working with Jeff and others on this for some time and we appreciate all of the work that they have done. The draft letter provides a limited approval period and indicates that the investigator must submit an amendment or new IRB application for full IRB approval of the project prior to the expiration date. It also emphasizes that no work with human subjects, including recruitment, may be conducted under the determination. Establishing a time limit, whether it is 3 or 6 months, requires investigators to return to the IRB and establishes accountability. Please contact Lisa Nichols if you have questions or concerns about the use of this draft letter.

COGR February 2016 Meeting Report Now Available

COGR's February 2016 Update

COGR February 25-26, 2016 Meeting Agenda Now Available

COGR's December 2015 Update

COGR has released the December 2015 Update

 [Full Text] [Summary]

COGR Submits Comment Letter to NSF on Research Terms and Conditions

Register Now For the Next COGR Meeting- February 25-26, 2016

NIH Releases 2015 Revised Grants Policy Statement

November 13, 2015: COGR Submits Letter to OMB on Utility Cost Adjustment Methodology

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October 2015 COGR Meeting Report Published

October 28, 2015- COGR Responds to Part 1 of the National Academies Report

2015-2016 COGR Meeting Dates Published

September 24, 2015 COGR Letter to OMB on UG Deviations

August 17, 2015 - August 2015 COGR Update COGR has published its August 2015 Update.

July 27, 2015: COGR Submits Comments to GSA on FAR Case 2014-025 Fair Pay and Safe Workplace

May 26, 2015 - May 2015 Update

May 8, 2015 - June 2015 COGR Meeting Agenda

April 24, 2015 - Comment Letter to the FAA on Proposed Rule for the Operation and Certification of Unmanned Aircraft Systems

COGR signed on to a comment letter to the FAA on its proposed rule for the Operation and Certiification of Small Unmanned Aircraft System.

February 20, 2015 - COGR Letter to EPA on Interim Conflict of Interest Policy

Posted February 20, 2015

January 22, 2015 - COGR Letter to OHRP on Draft Guidance on Disclosing Reasonably Foreseeable Risks in Research Evaluating Standards of Care

COGR sent a letter to the Office for Human Research Protections on draft guidance concerning disclosure of reasonably foreseeable risks in research evaluating standards of care.