Reporting and DATA Act Open Dialogue Grantees

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 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 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 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 »

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 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 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 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 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 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 »

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 »

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 »

Suggestions on how the benefits of the Performance Measures could be enhanced and the burdens of reporting could be reduced.

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 »

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 »

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 »

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 »

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.

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 »

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 »

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 »

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 »

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.

Suggestions on how the benefits of the Performance Measures could be enhanced and the burdens of reporting could be reduced.

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 »

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 »

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 »

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 »

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.

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 »

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 »

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 »

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 »

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.