COGR Requests More Time To Comment on OMB’s Proposed Rule
It was only a matter of time. COGR sent a letter this week to the Office of Management and Budget (OMB) requesting more time to comment on OMB’s proposed revisions to Title 2 of the Code of Federal Regulations, including the uniform guidance at 2 C.F.R. Part 200. This is something we fully expected to see; it was only a matter of when. Frankly, we suspect COGR won’t be the only stakeholder submitting such a request.
After issuing the proposed revisions on May 29, OMB provided at 45-day comment period, setting a July 13 deadline for stakeholders to submit comments. COGR, which represents nationwide research universities, medical centers and research institutes, requested a 45-day extension to respond to the changes, noting that the current 45-day window to respond is “an inadequate amount to time to fully assess and respond to the extensive and very significant changes” to the guidance.
COGR deemed the proposal “one of the most transformative revisions to the framework governing federal financial assistance” since the establishment of the uniform guidance in 2013. “These extensive changes, as proposed, would cause extraordinarily harmful consequences for federal research grantmaking and American research and innovation leadership and competitiveness,” wrote COGR President Matt Owens. “The proposed changes would effectively dismantle a framework that has supported basic and applied research in the U.S. and add unnecessary restrictions, requirements and substantial burden that will hamper U.S. leadership and competitiveness. This would be a sweeping change that warrants careful analysis and attention by stakeholders in forming their public comments on the proposed rule.”
The letter referred to a regulatory impact analysis of the proposal that notes limitations in current data to understand implementation costs, administrative burdens and operational effects. “Because OMB is expressly relying upon public comments to provide information necessary to evaluate the proposal, the adequacy of the administrative record will depend in substantial part on the ability of affected stakeholders to conduct meaningful analysis and provide empirical data regarding implementation impacts,” according to COGR.
COGR concludes to state that a 90-day, or even 120-day, comment period would be appropriate for “broad and significant changes of this scale,” and would allow stakeholders to “provide cost burden estimates, operational assessments, implementation information that OMB has identified as lacking, and the factual basis supporting any final rule.”
Regardless of COGR’s reasoning, the odds that OMB agrees to an extended comment period are relatively slim as OMB mentioned in the proposed rule that it aims to make the proposed revisions effective as of Oct. 1 to implement for federal fiscal year 2027 awards, which would be an unprecedented 18-week implementation period from the announcement of the proposed rule to making it effective. We’ll continue to watch for any updates to the comment period if they were to emerge.
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