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4 Regulations and Policies Related to the Acquisition and Use of Federal Research Grants
Pages 59-84

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From page 59...
... The specific areas of consideration are proposal preparation, progress reporting, and subrecipient monitoring. PROPOSAL PREPARATION 1 At its core, proposal preparation is an act of scholarship, as the creation of a research proposal is fundamentally an intellectual process that provides the investigator with an occasion to articulate the importance of a particular scientific question and to offer a strategy for addressing that question.
From page 60...
... 2 Regrettably, however, a significant portion of the information that must be submitted as part of a grant proposal package has little utility when it comes to evaluating the scientific merit of proposed research or the capabilities of the research team. Proposal preparation has become, in large measure, an administrative activity that dampens scientific ferment and imposes undue burdens on the researcher, his or her institution, and those engaged in proposal review.
From page 61...
... gov/pubs/2014/nsb1432/nsb1432.pdf. 6 See "Research Project Success Rates by NIH Institute for 2014," National Institutes of Health, Research Portfolio Online Reporting Tools (RePORT)
From page 62...
... 9 In most instances, granting agencies have long-term relationships with the researcher's academic institution and are well placed to make assessments regarding organizational legitimacy for managing funds and overseeing the conduct of research absent all of the detailed information currently required in proposal packages. Research institutions frequently seek accreditation of their programs and facilities by independent accrediting bodies, maintaining, for example, accredited human research protection and animal care and use programs.
From page 63...
... Research agencies and universities have worked diligently through both the Research Business Models Subcommittee of the National Science and Technology Council and the Federal Demonstration Partnership to standardize the forms and formats involved in the grant application process. Yet, despite best efforts, formats still vary widely across agencies, leaving faculty and their institutions to track and respond to very different and burdensome requirements.
From page 64...
... refers to information that is sent to a federal funding agency after an application package goes through initial scientific merit peer review and is deemed likely to be funded. Certain NIH programs and award mechanisms currently use JIT procedures for some information, and according to NIH, the "procedure reduces the time to award while ensuring the accuracy and timeliness of information needed to award NIH grants" 16 while decreasing "the administrative burden for the 7580 percent of the applications that will not receive funding." 17 If JIT procedures were employed for the submission of all documents that do not bear directly on the scientific merit of a proposal or provide critical assurances and biographical and budgetary information, a grant application might be reduced to the following components: Details on the Applying Institution Biosketch of Principal Investigator and Key Research Personnel Abstract Describing the Proposed Research Research Plan Total Estimated Budget Amount and If human subjects, animals and/or select agents are involved, the appli cation package would demonstrate that the institution has the necessary 15 Burden estimates are split between various OMB approval numbers and are inconsistent with regard both to the estimates listed on the forms and approvals.
From page 65...
... on the progress of science or the application of those finding(s) to health or technology; and your specific role in the described work." The Selected Peer-Reviewed Publications section had asked applicants to list selected publications "based on importance to the field, and/or relevance to the proposed research." 20 In addition, websites used to collect application information vary from agency to agency, and grant applicants applying to multiple agencies must become familiar with the idiosyncrasies of the various interfaces.
From page 66...
... RECOMMENDATIONS 4.1. The committee recommends that Congress, in concert with the White House Office of Management and Budget, conduct a transparent and comprehensive review of agency research grant proposal documents for the purpose of developing a uniform format to be used by all research funding agencies.
From page 67...
... 4.3. The committee recommends that research agencies develop a central repository to house assurances similar to the Single Audit Clearinghouse of the Federal Demonstration Partnership (FDP)
From page 68...
... 28 Recognizing that there was "inconsistency in interim research progress reporting among federal agencies," that interdisciplinary and interagency research is increasingly complex, and that "unnecessary variations" in progress reporting requirements "contribute to administrative burdens, take research time from investigators, and increase associated costs involved in the management of research programs, the Research Business Models Subcommittee of the Committee on Science launched an initiative that resulted in the creation of a "uniform Research Performance Progress Report (RPPR) format for use by agencies and awarding offices that support research and research-related activities." 29 24 But not social security numbers or financial information.
From page 69...
... They may, for instance, use optional components of the RPPR format to request additional information 31 and provide additional program-specific instructions necessary to clarify a requirement for a particular program. Agencies may also develop additional agency- or programspecific reporting components 32 and use other reporting formats, such as the Performance Progress Report, if those formats are better suited to the agency's reporting requirements, for example, for research centers and institutes, clinical 30 The RPPR format was implemented under 2 CFR Part 215 [OMB Circular A-110, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations (2012)
From page 70...
... 34 The Department of Energy, for example, implemented the Research Performance Progress Report format on November 22, 2010. While all Department of Defense components awarding grants and cooperative agreements for research activities are subject to the implementation of the RPPR, it is not clear that the RPPR is used uniformly by the Department of Defense.
From page 71...
... 38 See "Final Format: Research Performance Progress Report," National Science Foundation, 2010, accessed August 12, 2015, https://www.nsf.gov/bfa/dias/policy/rppr/ format_ombostp.pdf.
From page 72...
... ." See "Components and Significant Changes," National Science Foundation, accessed August 12, 2015, http://nsf.gov/bfa/dias/policy/rppr/frppr_sigchanges.pdf, and "Draft Format For Use in Submission of Interim and Final Research Performance Progress Reports," National Science Foundation, accessed August 12, 2015, http://nsf.gov/bfa/dias/ policy/rppr/frpprformat_fedreg.pdf.
From page 73...
... to collect data. The length of the three agencies' RPPR instructional doc uments provides an indication of the relative scope of their progress reporting in formation requirements: "NIH and Other PHS Agency Research Performance Progress Report (RPPR)
From page 74...
... d Inclusive of the "DOE F 4600.2, Financial Assistance Reporting Checklist for RD and D" and "Attachment 1, Research Performance Progress Report." In addition, by asking pointed questions regarding the direction research is taking or has taken, funding agencies may affect the course of scientific discovery, as investigators may feel the need to adhere strictly to the goals of the proposal rather than pursue promising avenues of inquiry as they appear. An investigator may feel safer reporting that the major goals and objectives of the project have not changed rather than providing an explanation for new directions given uncertainties as to how deviations from stated objectives might be viewed by the funder.
From page 75...
... . Subrecipient monitoring requirements are found in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, hereafter the Uniform Guidance.
From page 76...
... Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (4) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal government or, if no such rate exists, either a rate negotiated between the pass-through entity and the subrecipient…or a de minimis indirect cost rate…; (5)
From page 77...
... whether the subrecipient has new personnel or new or substantially changed systems; and BOX 4-2 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (The Uniform Guidance) "To deliver on the promise of a 21st-Century government that is more efficient, effective and transparent," the Office of Management and Budget issued the Uniform Guidance in an effort to streamline the federal government's guidance on administrative requirements, cost principles, and audit requirements for a federal awards.
From page 78...
... ] and "a non-Federal entity that expends less than $750,000 during the non-Federal entity's fiscal year in Federal awards is exempt from Federal audit requirements for that year, except…in...relation to other audit requirements [Audit Requirements, 2 CFR § 200.501 (d)
From page 79...
... . Similar language exists with respect to the monitoring of subrecipient human subject research: "In accepting an award that supports human subjects research, the recipient institution assumes responsibility for all research conducted under the award, including protection of human subjects at all participating and consortium sites, and for ensuring that an FWA and certification of IRB review and approval exists for each site before human subjects research may begin." (See NIH Grants Policy Statement (Washington, DC: U.S.
From page 80...
... Further, one institution may be both a "prime" recipient of multiple grants from federal research agencies and simultaneously a "subrecipient" collaborating on many research projects. Given that the vast majority of federally funded research takes place within the top 100 institutions that receive such funding, this means that the majority of subrecipient activity takes place between and among peer institutions that are subject to the same single audit requirements.
From page 81...
... 57 Further, in addition to the administrative burden that increased subrecipient monitoring imposes on research entities, institutions serving as partners in research will inevitably face conflicts by virtue of their position as both overseers and collaborators. Findings One of the purposes of the Single Audit Act was to reduce burdens on nonprofit organizations by promoting sound financial management of federal awards "administered by non-Federal entities." Research institutions are not administering federal awards per se.
From page 82...
... RECOMMENDATIONS 4.6. The committee recommends that the White House Office of Management and Budget amend the Uniform Guidance to clarify that subrecipient monitoring requirements apply to institutions of higher education only to the extent necessary for prudent project and performance monitoring, and do not require more extensive monitoring of subrecipients' institutional compliance with all federal statues, regulations, policies, and institutionwide business practices.
From page 83...
... Regulations & Policies Related to the Acquisition and Use of Federal Grants 83 As an immediate, interim measure, the committee recommends that the Office of Management and Budget permit research institutions to use subrecipients' publicly available Single Audit Reports to verify that subrecipients have not been otherwise debarred or suspended with respect to the receipt of federal funds. For those with a clean Single Audit Report, the prime institution should be allowed to rely on the Single Audit Act oversight process as an alternative to conducting a review of the adequacy of the subrecipient's institutional systems and business practices.


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