Based on the lack of any perceptible value for the agencies or the public, we recommend that Congress repeal the mandate for reporting on executive compensation and that the FAR Council subsequently revise the relevant contract clauses. Doing so will save millions of dollars and liberate additional contractor and government resources to focus on what matters most—achieving the missions of the federal government and serving ...more »
The FAR requires semi-annual submission of Individual Subcontract Reports (ISRs) for all federal agencies, as well as Summary Subcontract Reports (SSRs) for DoD and NASA, and annual submission of SSRs for civilian agencies. In addition to the submissions required during performance of a covered contract, ISRs are required to be submitted within 30 days of contract completion. Amending the FAR, at a minimum, and the ...more »
The grant period usually does not match with the term of a graduate student or a post-doc exactly. Therefore, if one allows institution to approve the budget re-allocation between graduate students and post-docs, instead of seeking approval from funding agency, that will make research go more smoothly based on the need of individual project.
AAU, COGR, and APLU recommend that OMB require all Federal agencies subject to OSTP’s 2013 policy memorandum, “Increasing Access to the Results of Federally Funded Scientific Research,” to harmonize the procedures by which extramural grantees submit final peer-reviewed manuscripts or final published documents and data to the agencies’ public access repositories. We believe that this harmonization process may most effectively ...more »
The Federal Acquisition Regulation (FAR) requires federal service contractors to report their direct labor hours and amounts invoiced to the government. This mandate is intended to help federal agencies fulfill their annual requirement to submit to the Office of Management and Budget (OMB) an inventory of activities performed by service contractors, in order to help determine whether agencies have the right balance of ...more »
Institutions must manage data for multiple highly complex loan, grant, and work study sources for Title IV aid. Creating uniform interfaces and navigation across existing systems would assist the administrators responsible for maintaining data in multiple portals.
In at least some areas of NSF there is a two-stage proposal process: A short preliminary proposal goes to an initial screening. If it passes that initial screening then a full proposal must be written. I would propose that NEH adopt this process as well. Given the intense competition for NEH grants, with a success rate hovering around 15%, although for the most competitive grants it’s about 6%. Writing grants is a ...more »
Currently Modified Total Direct Cost (MTDC) only allows inclusion of subcontracts up to the first $25,000 of each subaward or subcontract (regardless of the period of performance of the subawards and subcontracts under the award). We suggest increasing this to the first $50,000.
Harmonize Requirements and Standardized Collection of Non-Financial Training Prior to Issuance of an Award - Non-Financial Investigator training requirements (e.g. Financial Conflict of Interest, Responsible Conduct of Research, Research with Human Subjects), are convoluted because acceptable subject matter and timelines for completion vary by agency. Non-financial training requirements should be harmonized to reduce ...more »
2. Eliminate Two Layer IRB and IACUC Review of Human and Vertebrate Animal Research - Institutions receiving federal funds for research with human subjects or vertebrate animals are required to maintain a Federal-wide Assurance (FWA) or Animal Welfare Assurance (AWA) with the DHHS Office of Human Research Protections (OHRP) or Office of Laboratory Animal Welfare (OLAW), respectively. Institutions thereby accept the responsibility ...more »
1. Achieve a true single audit. IHEs are still subject to multiple audits of their individual programs and compliance processes, despite the Single Audit Act of 1984, OMB Circular A-133 and 2CFR-200 Uniform Guidance which mandate single audits for non-federal entities that receive federal funding. The University is subject to a major compliance audit, desk audits and program audits each year.
1. Achieve a true single audit. IHEs are still subject to multiple audits of their individual programs and compliance processes, despite the Single Audit Act of 1984, OMB Circular A-133 and 2CFR-200 Uniform Guidance which mandate single audits for non-federal entities that receive federal funding. The University is subject to a major compliance audit, desk audits and program audits each year.
Government understandably wants to data-mine progress reports. The loss of Fastlane reporting, with its PDF structure, in exchange for plain text/fillable fields in Research.gov, is an example of this. However, the reporting format in Research.gov is ridiculously time-consuming. It has generated an extreme, labor-intensive, administrative burden. Not one Principle Investigator I know wants anything to do with Research.gov, ...more »
I spend more time figuring out what I have to report than actually reporting it. If the process could be streamlined with fillable forms, this would make it much easier!
For each person paid from the grant who worked >160 hours (1 person month) during the grant year, there must be a Commons ID (including the completion of Personal Profile Information). There also needs to be information about the total number of hours each person worked on the grant during grant year so that person months can be calculated. This information is required for undergraduate who may be paid hourly as student ...more »
The requirement to list PubMed Central ID #s is a HUGE time and effort burden for research administrators. That is the #1 requirement I would change. There must be other ways to track compliance with the Public Access Policy.
Right now the federal conflict of interest statements are due at the application and then reconfirmed upon award. Since most grants aren't funded, it would save hours of time to not have this due until the Just in time documents.
Effort Reporting should be incorporated into the progress reports. some sponsors want person months and descriptions of person(s) tasks.
Change UG to Allow 120 Days for all Final Reporting (Financial and Programmatic) for all agencies Currently the Uniform Guidance (UG) requires that all financial & programmatic reports are submitted to the sponsor within 90 days after end date. Several agencies, through coordination with the FDP (Federal Demonstration Partnership) and COGR, are adjusting their deadlines to 120 days after end-date. These agencies, most ...more »
Enactment of the Digital Accountability and Transparency Act in May, 2014 provides many opportunities for the Office of Management and Budget and the Department of Treasury to improve the public transparency of Federal spending while simultaneously reducing the overall reporting burden on both Principal Investigators and institutional Research Administrators. However, there are also many implementation scenarios that ...more »
A single, central reporting portal for all reporting would help achieve the goals of the DATA Act. A central portal should provide the following functions: 1) One Portal a. The goal is to have one place for recipients to report on research expenditures. b. All the agencies conform from the beginning. i. If exceptions are granted, it should be clearly documented who has been granted an exception and, the length of time ...more »
Limit the public release of federal audit reports until they have been validated through audit resolution. Since universities are reputation-based organizations, great harm can result from premature release of audit reports that are later found to be out of step with agency policy. In addition, and as a result of some universities efforts to be 100% compliant, premature release of audit reports can result in the enactment ...more »
Consider an effort to have PUBLIC LAW 96-511—DEC. 11, 1980 (Paper Reduction Act) updated or encourage a new public law so as to change the focus to reducing administrative burden (i.e. creation of a “Administrative Burden Reduction Act”). The goal would be to (1) engage the research community on an ongoing basis to create efficiencies, (2) encompass a risk analysis for all types of administrative activities to match ...more »
OMB should clarify the parameters for the risk analyses that universities are required to make for their subrecipients under the Uniform Guidance. Such a move would help to curtail the proliferation of individualized standards or action plans established by individual universities seeking to carry out their responsibilities under the as prime recipients with respect to their subrecipients.
The government should make efforts to reduce focus on the micro accounting of grant expenditures and move towards a system where the peer review process and program managers base future funding decisions on broader measures of appropriate expenditures of cost. Princeton University suggests that one useful guide might be the IRS rules: in general, any expenditure that would normally be considered taxable income (apart ...more »
PIs at Princeton University spend a large amount of their time during proposal preparation on compliance approvals. One recommendation would be for the federal government to impose a pre-compliance standard at submission, which could include a document from the sponsored research office listing areas where they know that strict compliance has not been met. The compliance can then be fully implemented once/if the proposal ...more »
Faculty at Princeton University find it frustrating that each agency requires different data in different formats and that not all the web portals work well. For example, the DOE-BES PAMS system does not always save entries, and this can lead to loss of edits. Clicking to save an entry often takes the PI to the login page, often resulting in loss of data. So having a robust portal that automatically saves data entered ...more »
Given that the main product of federally-funded research is typically publications, Princeton University suggests that it would seem sensible to allow submission of PDFs of publications where they have already appeared as a result of the work funded by the grant, and reduce the reliance on extensive research summaries. If nothing has been published, then it makes sense to ask for a report on preliminary progress. NSF ...more »
Princeton University submits that the Uniform Guidance benefits higher education institutions in many ways, but only so long as the federal awarding agencies interpret the rules of the Uniform Guidance consistently. The following captures a few areas where consistency is needed: A. Sections 200.203(a)(5), Notice of funding opportunities (CFDA Numbers), and 200.301, Performance measurement – neither of these sections ...more »
Codify the Frequently Asked Questions (FAQs) to eliminate potential interpretation differences of future auditors and inspectors general between Uniform Guidance and FAQs.
Princeton University suggests that the Federal Audit Clearinghouse (FAC) should provide more guidance (e.g. definitions, acronyms) on how to access and leverage annual reports to monitor subrecipients per Uniform Guidance requirements in order to reduce the burden. Assistance in navigating through the forms similar to guidance provided to comply with the Federal Funding Accountability and Transparency Act (FFATA) would ...more »
The OMB Compliance Supplement for the Single Audit increased the threshold for known or likely questioned costs from $10,000 to $25,000. Princeton University suggests that consideration should be given for a threshold higher than $25,000, particularly when extrapolation could occur throughout the rest of the organization. An alternative solution would be to make the threshold related to a percentage of expenditures ...more »
The RPPR continues to evolve into more financial and administrative reporting than it has to do with scientific/technical progress ever since you eliminated annual FFR's for SNAP grants. Institutions are getting hammered on follow-up questioning from Grants Mgmt Specialists regarding unobligated balances, effort reported on the participants tab, other support, use of IDP's and MyNCBI noncompliant pubs. Many followup ...more »
Grant Proposals indicate all institutions involved and require separate budget submissions. Not only is it a waste of taxpayer $ to pay institutions F&A on the first 25K of each sub, but it is so inefficient to dole out the $ to us to turn around and pay out the subs when you can utilize a LOC payment system. Then you impose subrecipient monitoring on us and everybody has to document everyone else's audit report/FCOI ...more »
Research administrators work in a world of constant and continuous audits by various Federal OIGs. These are in addition to the ongoing annual "A-133" audits designed to attest to our having systems and procedures in place to provide proper stewardship over Federal funds under our purview. The OIG audits have been extremely aggressive and are characterized by initial allegations of wrongdoing, high cost disallowances, ...more »
Since the publication of the Uniform Guidance UG), institutions have seen various Conflict of Interest (COI) terms and conditions embedded within broad agency announcements and proposal solicitations, despite the lack of formal agency-wide policies or guidelines in most cases. The specific requirements for what financial interests and relationships need to be disclosed, the nature and timing of reviews, and even definitions ...more »
Since the implementation of the PHS requirements for disclosure of potential financial conflicts of interest for all key personnel at the time of proposal, this has been one of the most burdensome requirements for Faculty and staff at the University of Chicago. Last year alone we were required to obtain over 5,000 disclosures of financial interests before PHS proposals could be submitted, while only 115 of those disclosures ...more »
Section 5 of the DATA Act of 2014 requires the Office of Management and Budget (OMB) to establish a pilot program to test whether standardizing the data elements used in recipient reporting can reduce the burden that grantees and contractors experience in reporting on the federal funds that they receive and spend. In this fiscal year, federal agencies have awarded $540 billion in grants and $297 billion in contracts. ...more »
Allow for easier way to obtain and record RSVP volunteer timesheets. Currently the signature piece is unclear. As long as the supervisor at the site signs off that should be more than enough.
There is much redundancy in the current reporting. Suggest the following: 1) one annual Progress Report 2) Performance Measure surveys ONLY to be done ONCE in the 3 year grant period 3) when submitting renewal grants if the workplans are not changes have a box to simply check that off. 4) same for budgets 5) Accessability and Site Safety checks only to be done ONCE in the 3 year grant period and reflected in the MOU. ...more »
AAU, COGR and APLU recommend that OMB require Federal agencies to adopt common research terms and conditions. We believe NSF, NIH, USDA NIFA, NIST, NOAA, DOE, FAA, EPA and NASA are creating common RTCs, but other agencies have opted out. Clear and consistent data definitions are also needed. Not all federal agencies are signing on to federal-wide research terms and conditions for federal awards under the Uniform Guidance ...more »
AAU, COGR and APLU recommend that OMB eliminate the DS-2 requirement for institutions of higher education. The DS-2 is a document setting forth an institution’s accounting practices with regard to federal funds that requires approval by the institution’s cognizant agency for indirect costs. It is a transposition of accounting policies and practices that are already documented elsewhere, usually on an institution’s website ...more »
AAU, COGR and APLU recommend that OMB raise the micropurchase threshold from $3,000 to $10,000 to reflect current practices. As data supports a higher threshold, OMB should consider future adjustments. The UG has introduced a category known as “Micro-Purchases,” defined as purchase transactions up to $3,000, below which there is no requirement to document competition. This was not included in the proposed guidance so ...more »
AAU, COGR and APLU recommend that OMB strongly encourage Federal agencies to issue collaborative/linked awards as an alternative to subawards. Separately submitted collaborative proposals allow two or more PIs/institutions to manage separate awards for a single, unified project.
AAU, COGR and APLU recommend that OMB clarify that where a subrecipient has a current Single Audit report, prime recipients can rely on the subrecipient’s auditors and cognizant agency oversight for routine audit follow-up and management decisions. Science is engendering an increased number of collaborative projects, resulting in significant growth in the number of subawards issued and received by institutions of higher ...more »
AAU, COGR, and APLU recommend that OMB and federal research funding agencies and/or cognizant agencies work with the research community to explore the optional use of alternatives to measures of time as a means of assessing proper use of federal funds (e.g., information provided in progress reports and publications as an alternative to documenting personnel charges) as well as means of reducing reporting requirements. ...more »
AAU, COGR and APLU recommend that OMB clarify the conflict of interest regulations in section 200.112 of the Uniform Guidance. OMB should make a technical correction to the UG, removing “selection of a subrecipient” to clarify that the intent of the regulations is to address conflicts that might arise around how a non-Federal entity expends funds under a Federal award and not to individual financial interests and work ...more »
AAU, COGR and APLU recommend that OMB clarify in regulation that personal activity reports are not required under the Uniform Guidance (UG); that awardees do not have to certify payroll expenses; and that cognizant agency approval is not needed to implement alternatives to effort reporting that meet the UG standards of documentation. The Uniform Guidance provides institutions with increased flexibility to document ...more »
AAU, COGR and APLU recommend that agencies eliminate quarterly financial reports once they have transitioned to subaccounts. Institutions draw down cash by award accounts on a regular basis, typically monthly. This provides agencies with up-to-date financial information and renders additional financial reports unnecessary. Agencies should also consider whether there is a need for annual and final financial reports and ...more »
AAU, COGR and APLU recommend a common federal portal for grants submission, invoicing/cash draw downs, and final reporting (e.g., progress, financial, equipment) with a single set of rules, forms and due dates (potentially using NSF policy and guidelines as a model). A common portal would significantly ease reporting burden. - Consolidate federal proposal and award management systems, including payment systems, optimally ...more »
Review existing agency financial reporting regulations to eliminate intra and interagency redundancy.
Eliminate multiple federal payment systems. Financial reporting is unnecessarily complex due to variations across Federal agency systems.
If a centralized reporting database could be developed that all federal agencies, grantees, subrecipients, etc. would be required to use for reporting, and it would prepopulate many of the fields once the entity enters their FAIN, this would ease a lot of the reporting burden.
However, first, the FAIN would have to start being included in grant agreements so entities have that piece of information to enter.
Last year, the Coalition for Government Procurement submitted a number of recommendations in response to the Chief Acquisition Officers Council (CAO) Council Open Dialogue to improve the economy and efficiency of the Federal acquisition system. The Coalition urges the government to take action on the previously submitted recommendations to increase the efficiency and the effectiveness of Federal procurement. Implementing ...more »
I am surprised more people haven't been commenting or making suggestions. Do you think it might be due to the fact that most of us are so busy with our jobs, lacking funds, burnt out and trying to pick up pieces of pie because we are spending our own time working and ignoring everything else? Our jobs have become so complicated with reporting and regulations that we don't have time to take care of the people and partners ...more »
Comment from June 10 Data Act Summit breakout session on Recipient Reporting:
As a Federal Award recipient , I would like the ability to submit a single financial report to single place that would be used each agency for its own purposes.
Comment from June 10 Data Act Summit breakout session on Recipient Reporting:
As a Federal Award recipient, I want to easily correct errors I find in government data systems. I want to be able to alert the contracting office, for them to quickly make a correction, for this process to be seamless.
Comment from June 10 Data Act Summit breakout session on Recipient Reporting: As a Federal Award recipient, I want transactional data reporting to be a more efficient method than a weekly form. There’s a need to minimize weekly re-entry of the same information that was submitted previously. Also the government already has a lot of this information, so the recipient should only be required to report what the government ...more »
Comment from June 10 Data Act Summit breakout session on Recipient Reporting:
As a Federal Award recipient, I want to see more pre-populated forms and drop-down options to minimize the burden of completing reporting.
Comment from June 10 Data Act Summit breakout session on Recipient Reporting:
There needs to be alignment of Federal Spending elements and the elements in the CDERL and elements like entity classification
Comment from June 10 Data Act Summit breakout session on Recipient Reporting:
I’m interested in Entity Classifications- better classifications, better utilization of existing classifications. I want to, for example, be able to look in USASpending.gov and analyze the dollars going to non-profits.
Comment from June 10 Data Act Summit breakout session on Recipient Reporting:
As a Federal contract recipient, I want performance reporting to be in one place.
Currently, the submission to the Federal Audit Clearinghouse requires a PDF file (Single Audit Reporting Package/Audit Report Package) in addition to some of the same data provided in Form SF-SAC. Since all of the components of the Single Audit Reporting Package are posted on websites, I suggest we provide links to these documents rather than create a PDF of all of the documents. In addition, the format we use for our ...more »
Do the feds have a formula they want us to use when reporting on partner stations that DO NOT collect unduplicated individuals served? Every year we run up against this issue and how to dissect a number of all served, usually duplicated, to how that breaks down as far as number of individuals served by RSVP volunteers.
Suggestions on how the benefits of the Performance Measures could be enhanced and the burdens of reporting could be reduced.