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.