Comment Letters

COGR Endorses AUECO Comment Letter to BIS on Export Administration Regulations: Crime Controls and Expansion/Update of U.S. Persons Controls - read more...

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 - read more...

COGR Responds to Request for Comments: Biosketch and Current and Pending Support Disclosure Policy - read more...

COGR Responds to Advance Notice of Proposed Rulemaking - "Provisions Regarding Access to Americans' Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern" - read more...

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” - read more...

COGR, EDUCAUSE, and AAU Submit Joint Comment Letter to GSA on Cyber Threat and Incident Reporting & Information Sharing (FAR 2021-017) - read more...

University Association Comments to NIST - read more...

COGR Submits Comments to ORI on Public Health Service Policies on Research Misconduct Notice of Proposed Rulemaking - read more...

COGR Submits Joint Association Request for Extension of Comment Period for Oct. 6, 2023, NPRM on PHS Policies on Research Misconduct (88 FR 69583) - 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 Submits Comment Letter in Response to Notice to Announce NIH Updated Policy Guidance for Subaward/Consortium Written Agreements (88 FR 36603) - read more...

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 - read more...

COGR Supports EDUCAUSE Response to NIST's Cybersecurity for R&D Request for Comment - read more...

COGR Responds to OSTP Request for Information: NSPM 33 Research Security Programs Standard Requirement (88 FR 14187) - read more...

COGR Submits Joint Association Request to OSTP for Listening Sessions on Research Security Programs Standards - read more...

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

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...

Multi-Association Follow Up Letter to DoEd on Section 117 - read more...

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. 

COGR Submits Comment Letter to OSTP Concerning January 2022 Guidance for Implementing NSPM-33 - read more...

This letter contains COGR’s comments regarding the Implementation Guidance for National Security Presidential Memorandum 33, and stresses the need for transparency, a risk-based approach, and cross-agency consistency. 

COGR Submits Letter to OSTP on Reducing Administrative Burden - read more...

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) - read more...

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, AAU, and APLU Submit Letter to DOE on Order 142.3B - read more...

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

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.

Joint Association Comment Letter Regarding Foundational Technologies ANPRM - read more...

Posted November 2020

This letter contains joint association comments regarding concerns associated with potential expansion of controls on foundational technologies. 

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]

Joint Association Letter to NIST on Protecting Controlled Unclassified Information SP800-171B - read more...

Posted August 2, 2019

This letter sets forth joint association comments expressing questions and concerns about how sponsoring agencies will apply the enhanced requirements of NIST SP 800-171B.

Association Response to DoEd on Section 117 Reporting - read more...

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. 

Joint Association Comment Letter on Emerging Technologies ANPRM - read more...

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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).

Joint Association Memo Requesting Extension from BIS - read more...

Posted December 4, 2018

This letter contains a joint association request for an extension to provide comments in response to the Advance Notice of Proposed Rulemaking (ANPRM) on the “Review of Controls for Certain Emerging Technologies published by the Bureau of Industry and Security (BIS) in the Federal Register on November 19, 2018.

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

Posted 5/29/18

This letter contains COGR's comments seeking DOD clarification that SSPs and NIST compliance is not required in contracts or subcontracts involving solely the performance of fundamental research, and/or research not involving any covered defense information or other types of controlled unclassified information.

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.” 

Letter from National Security Advisor to CSIS

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This is a copy of a letter from Dr. Rice, National Security Advisor to the President in response to a letter from COGR on the Future of Technology and Public Policy regarding export controls and fundamental research.