Other Financial Management & Compliance

COGR Responds to NIH Proposed Collection of Post-Award Reporting Requirements - read more...

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 - read more...

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

COGR Responds to OMB's NPRM on Guidance for Grants & Agreements "Uniform Guidance" - read more...

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) - read more...

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 - read more...

Results from the COGR Survey on the Cost of Complying with the New NIH DMS Policy - read more...

COGR Responds to OMB's RFI: Uniform Guidance (2 CFR 200) - read more...

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 Posts DRAFT Response to OMB (Uniform Guidance) - read more...

COGR's 2 CFR 200 "Uniform Guidance" Resource Page - read more...

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

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

COGR's NIH Data Management and Sharing Readiness Guide: Chapter 4 Part II, Project-Based and Institutional Cost Considerations - Budgeting & Costing - read more...

COGR Releases NIH DMS Readiness Guide Chapter 4 Part II - Budgeting and Costing: Project-Based and Institutional Cost Considerations - read more...

Chapter 3 Part II of COGR's NIH DMS Readiness Guide: Roles and Responsibilities (Excel Download) Now Available - read more...

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

COGR Submits Comments to OMB Regarding the 2022 Compliance Supplement - read more...

UPDATE & ERRATA TO COGR NOVEMBER 2021 UPDATE - read more...

Posted December 15, 2021

COGR Submits Comments to DoEd on HEERF Data Collection Form Federal Register Notice - read more...

Posted November 8, 2021

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

Posted August 12, 2021

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

Posted April 21, 2021

Research Impact Under COVID-19: Financial Crisis and the "Pandemic Normal" - read more...

Posted August 25, 2020

COGR's Response to JCORE RFI - read more...

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 - read more...

Posted January 23, 2020

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

Posted April 12, 2019

Additional F&A Resources

HERD Survey Questions from COGR - read more...

Posted 3/21/19

Discussion Points on Facilities and Administrative Costs and Regulatory Reform - read more...

Associations Oppose Cuts to NIH Budget - read more...

COGR joined with over 100 other organizations Monday on a letter to Office of Management and Budget Director Mick Mulvaney and Health and Human Services Secretary Tom Price to oppose the proposed cuts to NIH funding and facilities and administrative (F&A) costs in the Administration's FY18 budget. 

Among other things, the letter states that "If the Administration’s proposal to reduce NIH support for F&A moves forward, it will make research unaffordable for many institutions and ultimately lead to less research carried out across the country", and that "the economic impact could also be significant; communities will lose jobs, and the country will fall behind as our foreign competitors forge ahead in medical research. These consequences will hurt patients, scientists, and all Americans."

COGR Submits Joint Association Letter on DOE Regulatory Reform - read more...

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 Letter to Mulvaney and Price Objecting to NIH and F&A Budget Cuts - read more...

Posted June 12, 2017

At OMB Request: Letter to Identify OMB Actions to Reduce Administrative Burden - read more...

Posted April 17, 2017

F&A Survey Results Available to COGR Membership

Click here.

Finances of Research Universities - June 2014 - read more...

“Finances of Research Universities” describes the financial landscape of research universities and calls for active collaboration among all stakeholders to address financial risks to the research enterprise in a productive manner.

Full Report

Summary

An Analysis of the DCA Best Practices Manual - COGR Interpretations

Click here to view the paper.

How to Conduct Non-Federal Stem Cell Research Without Violating the Federal Stem Cell Funding Prohibition

How to Conduct Non-Federal Stem Cell Research Without Violating the Federal Stem Cell Funding Prohibition
By Robert J. Kenny, Jr. [Medical Research Law and Policy Review, 2005]

National Institutes of Health Stem Cell Resource Web Site

Letter to Department of Labor on "Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees"

Click here to view

COGR Guide to 2 CFR 200.430 Compensation-Personal Services

Click here for the Guide.

COGR Readiness Document - Uniform Guidance -

Click here for the Guide. If interested in a Word version of the Guide, please contact David Kennedy.

COGR Response to Grants Reform

OMB Advance Notice of Proposed Guidance, April 2012. Click here for the letter.

COGR Proposal to the A-21 Task Force

Discontinuation of the Effort Reporting Requirement, November 2011. Click here for the proposal.

COGR Response to NIH RFI

 Input on Reduction of Cost and Burden Associated with Federal Cost Principles for Educational Institutions (OMB Circular A-21), July 2011.  Click here to view the Letter and here to view the Attachment.

Cost of Doing Business Study

Click here to view Study.
Click here to view Table of Contents.
Click here to view Inventory.

Managing Externally Funded Programs at Colleges and Universities: A Guideline to Good Management Practices

Click here to view