The American Council on Education (ACE), Association of American Universities (AAU), Association of Public and Land-grant Universities (APLU), COGR, and EDUCAUSE submitted comments on the proposed Federal Acquisition Regulation (FAR) rule regarding Controlled Unclassified Information (CUI), emphasizing the need for consistent definitions and exclusions for fundamental research across all fields. They also highlighted concerns about training burdens, reporting deadlines, and patent security requirements, advocating for adjustments to ensure that the final rule supports both CUI security and the efficient operation of higher education research institutions.
AAU responds to the Department of Justice's NPRM regarding preventing access to U.S. sensitive personal data and government-related data by countries of concern or covered persons. AAU requests clarification on whether this applies to non-commercial basic research and agrees with COGR that various categories of ‘omic data encompass a wide set of measurements related to human physiological, pathological, or genetic measurements that are used to help understand basic mechanisms or functions of human health states and that do not contain identifiable information.
AAU, and four higher education organizations, joined comments led by ACE to the Department of Education in response to the information comment request regarding proposed changes to the Integrated Postsecondary Education Data System (IPEDS). The letter emphasizes the value of IPEDS data stating “Our associations and member institutions are strongly committed to protecting and enhancing the value of IPEDS data and ensuring that this collection continues to provide accurate and useful data across the diverse landscape of higher education while at the same time working to minimize the reporting burden on our institutions.”
AAU, and other higher education organizations, joined comments led by ACE to the Department of Education regarding new financial value transparency (FVT) and gainful employment (GE) reporting requirements.
AAU, ACE, and four other higher education associations submit comments supporting the review and approval of the Interagency Edison (iEdison) System.
AAU submits comments to provide input in response to the “Dear Colleague” Letter issued by NSF on May 4, 2023 regarding the development of the U.S. Research Security and Integrity Information Sharing Analysis Organization; NSF 23-098.
AAU, ACE, and 12 other organizations in the higher education community submitted comments to to the National Science Foundation (NSF) regarding the Proposed Implementation of Proposal and Award Policies & Procedures (PAPPG) Chapter VII.D.3 "Foreign Gifts and Contracts Disclosure."
AAU has submitted comments in response to OSTP’s request for information on the draft NSPM-33 Research Security Programs Standard Requirement. The comments address overarching concerns including accounting for a risk-based approach and requesting clarity on the four program requirements: foreign travel security, research security training, cybersecurity, and export controls training.
AAU joined AUTM and COGR in sending a letter asking the United States International Trade Commission to reject TRIPS waivers for COVID-19 therapeutics and diagnostics.