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Ideas Contributed [ 11 ] [+]
Harmonize Agency Public Access Procedures and Submission
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 »
Voting
Require Agencies to Adopt Common Research Terms and Conditions
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 »
Voting
Eliminate the DS-2 Requirement for IHEs
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 »
Voting
Raise the Micropurchase Threshold to $10,000
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 »
Voting
Issue Collaborative Awards as an Alternative to Subawards
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.
Voting
Eliminate Prime Recipient Monitoring of Subs Subject to Audit
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 »
Voting
Explore Optional Use of Alternatives to Time and Effort
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 »
Voting
Clarify Conflict of Interest Regulations in the Uniform Guidance
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 »
Voting
Clarify in regs that Personal Activity Reports are not required
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 »
Voting
Eliminate Quarterly Financial Reports
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 »
Voting
Common Federal proposal and award management system
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 »