Federal Research Grants:

Opportunities Remain for Agencies to Streamline Administrative Requirements

GAO-16-573: Published: Jun 22, 2016. Publicly Released: Jul 22, 2016.

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What GAO Found

Administrative requirements for federal research grants include (1) Office of Management and Budget (OMB) government-wide grant requirements for protecting against waste, fraud, and abuse of funds and (2) agency-specific requirements generally for promoting the quality and effectiveness of federally funded research. For example, OMB requires grantees to maintain records sufficient to detail the history of procurement for all purchases made with grant funds, and the Department of Energy (DOE), National Aeronautics and Space Administration (NASA), National Institutes of Health (NIH), and National Science Foundation (NSF) require applicants to develop and submit biographical sketches describing their professional accomplishments so agencies can consider researchers' qualifications when deciding which proposals to fund.

Officials from universities and stakeholder organizations GAO interviewed identified common factors that add to their administrative workload and costs for complying with selected requirements: (1) variation in agencies' implementation of requirements, (2) pre-award requirements for applicants to develop and submit detailed documentation for grant proposals, and (3) increased prescriptiveness of certain requirements. They said that these factors add to universities' workload and costs in various ways, such as by causing universities to invest in new electronic systems or in the hiring or training of staff. For example, university officials told GAO that new OMB requirements for purchases made with grant funds will result in added costs for hiring administrative staff to handle an increased volume of purchases that are subject to some form of competition.

OMB and research funding agencies have made continuing efforts to reduce universities' administrative workload and costs for complying with selected requirements, with limited results. These included efforts in three areas: (1) standardizing requirements across agencies; (2) postponing certain pre-award requirements until after making a preliminary decision about an applicant's likelihood of funding; and (3) in some cases, allowing universities more flexibility to assess and manage risks for some requirements. For example, funding agencies have developed a standard set of administrative terms and conditions for research grants and a standard form for research progress reports. Such efforts are in accordance with federal goals, such as those in a 2011 executive order that calls for agencies to harmonize regulations and consider regulatory approaches that reduce burdens and maintain flexibility. However, opportunities exist in each of the three areas to further reduce universities' administrative workload and costs. First, efforts to standardize requirements have not fully addressed variations in agency implementation of requirements, such as agencies' forms and systems for collecting project budgets and biographical sketches. Second, funding agencies have not fully examined pre-award requirements to identify those—such as requirements for detailed budgets—that can be postponed. Third, some requirements—such as those for obtaining multiple quotations for small purchases—limit universities' flexibility to allocate administrative resources toward oversight of areas at greatest risk of improper use of research funds. Further efforts to standardize requirements, postpone pre-award requirements, and allow more flexibility for universities could help ensure agencies do not miss opportunities to reduce administrative workload and costs.

Why GAO Did This Study

The federal government obligated over $27 billion for university research in fiscal year 2015, according to NSF. To allow for oversight of these funds, Congress and research funding agencies established administrative requirements that universities must comply with as part of grants they apply for and receive. University stakeholders have studied and raised concerns about the workload and costs to comply with the requirements.

GAO was asked to review research grant requirements and their administrative workloads and costs. This report examines (1) the sources and goals of selected requirements, (2) factors affecting universities' administrative workload and costs for complying with the requirements, and (3) efforts by OMB and research funding agencies to reduce the requirements' administrative workload and costs, and the results of these efforts. GAO selected and examined in detail nine areas of administrative requirements at DOE, NASA, NIH, and NSF, and interviewed administrative staff and researchers from six universities. GAO selected agencies and universities that ranged in the amount and type of research funding provided or received.

What GAO Recommends

GAO recommends that OMB, DOE, NASA, NIH, and NSF identify additional areas where requirements, such as those for budgets or purchases, can be standardized, postponed, or made more flexible, while maintaining oversight of federal funds. DOE, NASA, and NIH generally concurred, and OMB and NSF did not comment on the recommendations.

For more information, contact John Neumann at (202) 512-3841 or neumannj@gao.gov.

Recommendations for Executive Action

  1. Status: Open

    Comments: As of July 2018, DOE had begun to address this recommendation through its participation in the interagency Research Business Models working group. In its May 2018 annual report under the American Innovation and Competitiveness Act, the working group identified potential ways to reduce the pre-award administrative workload of providing written assurances on each grant application that the applicant's home institution is in compliance with all applicable laws and regulations. In particular, the report cited development of a draft government-wide annual standard set of assurances for grant applicants and recipients, with the intent to establish a centralized service for the collection of and access to government-wide assurances that apply to grants.

    Recommendation: To reduce pre-award administrative workload and costs, particularly for applications that do not result in awards, the Secretary of Energy, the NASA Administrator, and the Secretary of Health and Human Services should conduct agency-wide reviews of possible actions, such as further use of preliminary proposals, to postpone pre-award requirements until after a preliminary decision about an applicant's likelihood of funding and, through OSTP's Research Business Models working group, coordinate and report on these efforts.

    Agency Affected: Department of Energy

  2. Status: Open

    Comments: HHS stated that, as of July 2018, NIH was considering (1) the feasibility of reducing the elements of an application that are requested initially and deferring their submission until after the completion of the peer review and prior to funding and (2) pilot programs to streamline the NIH application process further. HHS also participated in the interagency Research Business Models working group. In its May 2018 annual report under the American Innovation and Competitiveness Act, the working group identified potential ways to reduce the pre-award administrative workload of providing written assurances on each grant application that the applicant's home institution is in compliance with all applicable laws and regulations. In particular, the report cited development of a draft government-wide annual standard set of assurances for grant applicants and recipients, with the intent to establish a centralized service for the collection of and access to government-wide assurances that apply to grants.

    Recommendation: To reduce pre-award administrative workload and costs, particularly for applications that do not result in awards, the Secretary of Energy, the NASA Administrator, and the Secretary of Health and Human Services should conduct agency-wide reviews of possible actions, such as further use of preliminary proposals, to postpone pre-award requirements until after a preliminary decision about an applicant's likelihood of funding and, through OSTP's Research Business Models working group, coordinate and report on these efforts.

    Agency Affected: Department of Health and Human Services

  3. Status: Open

    Comments: As of December 2017, NASA anticipated implementing this recommendation by October 2018. In addition, NASA had begun to address this recommendation through its participation in the interagency Research Business Models working group. In its May 2018 annual report under the American Innovation and Competitiveness Act, the working group identified potential ways to reduce the pre-award administrative workload of providing written assurances on each grant application that the applicant's home institution is in compliance with all applicable laws and regulations. In particular, the report cited development of a draft government-wide annual standard set of assurances for grant applicants and recipients, with the intent to establish a centralized service for the collection of and access to government-wide assurances that apply to grants.

    Recommendation: To reduce pre-award administrative workload and costs, particularly for applications that do not result in awards, the Secretary of Energy, the NASA Administrator, and the Secretary of Health and Human Services should conduct agency-wide reviews of possible actions, such as further use of preliminary proposals, to postpone pre-award requirements until after a preliminary decision about an applicant's likelihood of funding and, through OSTP's Research Business Models working group, coordinate and report on these efforts.

    Agency Affected: National Aeronautics and Space Administration

  4. Status: Open

    Comments: HHS stated that, as of July 2018, NIH was proceeding with plans to assess the financial conflict of interest regulation, including how to reduce administrative burden on researchers while maintaining the integrity and credibility of research findings. HHS further stated that, under the 21st Century Cures Act, it has the lead responsibility to review of all regulations and policies related to the disclosure of financial conflicts of interest, including the minimum threshold for reporting financial conflicts of interests.

    Recommendation: To better target requirements on areas of greatest risk, while maintaining accountability over grant funds, the Secretary of Health and Human Services, as part of the planned evaluation of the HHS regulation governing financial conflicts of interest in NIH-funded research, should evaluate options for targeting requirements on areas of greatest risk for researcher conflicts, including adjusting the threshold and types of financial interests that need to be disclosed and the timing of disclosures.

    Agency Affected: Department of Health and Human Services

  5. Status: Open

    Priority recommendation

    Comments: As of September 2018, OMB had not provided information on steps it has taken to implement this recommendation.

    Recommendation: To better target requirements on areas of greatest risk, while maintaining accountability over grant funds, the Director of OMB, as part of OMB's planned evaluation of the Uniform Guidance, should evaluate options for targeting requirements for research grants to universities, including requirements for purchases and subrecipient monitoring, on areas of greatest risk for improper use of research funds.

    Agency Affected: Executive Office of the President: Office of Management and Budget

  6. Status: Open

    Comments: As of July 2018, DOE, HHS, NASA, and NSF had participated in an interagency effort that was beginning to identify additional areas for standardizing administrative requirements for federal research grants. In particular, in January 2017, the American Innovation and Competitiveness Act was signed into law, requiring establishment of an interagency working group to reduce administrative burdens on federally funded researchers while protecting the public interest through the transparency of and accountability for federally funded research. In May 2018, the Research Business Models working group, which includes representatives from DOE, HHS, NASA, NSF and other research-funding agencies, issued its first annual report under the act. The report identified several potential areas for standardization or harmonization of requirements, such as the policy for what constitutes a financial conflict of interest.

    Recommendation: To further standardize administrative research requirements, the Secretary of Energy, the NASA Administrator, the Secretary of Health and Human Services, and the Director of NSF should coordinate through Office of Science and Technology Policy's (OSTP) Research Business Models working group to identify additional areas where they can standardize requirements and report on these efforts.

    Agency Affected: Department of Energy

  7. Status: Open

    Priority recommendation

    Comments: As of July 2018, DOE, HHS, NASA, and NSF had participated in an interagency effort that was beginning to identify additional areas for standardizing administrative requirements for federal research grants. In particular, in January 2017, the American Innovation and Competitiveness Act was signed into law, requiring establishment of an interagency working group to reduce administrative burdens on federally funded researchers while protecting the public interest through the transparency of and accountability for federally funded research. In May 2018, the Research Business Models working group, which includes representatives from DOE, HHS, NASA, NSF and other research-funding agencies, issued its first annual report under the act. The report identified several potential areas for standardization or harmonization of requirements, such as the policy for what constitutes a financial conflict of interest.

    Recommendation: To further standardize administrative research requirements, the Secretary of Energy, the NASA Administrator, the Secretary of Health and Human Services, and the Director of NSF should coordinate through Office of Science and Technology Policy's (OSTP) Research Business Models working group to identify additional areas where they can standardize requirements and report on these efforts.

    Agency Affected: Department of Health and Human Services

  8. Status: Open

    Priority recommendation

    Comments: As of July 2018, DOE, HHS, NASA, and NSF had participated in an interagency effort that was beginning to identify additional areas for standardizing administrative requirements for federal research grants. In particular, in January 2017, the American Innovation and Competitiveness Act was signed into law, requiring establishment of an interagency working group to reduce administrative burdens on federally funded researchers while protecting the public interest through the transparency of and accountability for federally funded research. In May 2018, the Research Business Models working group, which includes representatives from DOE, HHS, NASA, NSF and other research-funding agencies, issued its first annual report under the act. The report identified several potential areas for standardization or harmonization of requirements, such as the policy for what constitutes a financial conflict of interest.

    Recommendation: To further standardize administrative research requirements, the Secretary of Energy, the NASA Administrator, the Secretary of Health and Human Services, and the Director of NSF should coordinate through Office of Science and Technology Policy's (OSTP) Research Business Models working group to identify additional areas where they can standardize requirements and report on these efforts.

    Agency Affected: National Aeronautics and Space Administration

  9. Status: Open

    Comments: As of July 2018, DOE, HHS, NASA, and NSF had participated in an interagency effort that was beginning to identify additional areas for standardizing administrative requirements for federal research grants. In particular, in January 2017, the American Innovation and Competitiveness Act was signed into law, requiring establishment of an interagency working group to reduce administrative burdens on federally funded researchers while protecting the public interest through the transparency of and accountability for federally funded research. In May 2018, the Research Business Models working group, which includes representatives from DOE, HHS, NASA, NSF and other research-funding agencies, issued its first annual report under the act. The report identified several potential areas for standardization or harmonization of requirements, such as the policy for what constitutes a financial conflict of interest.

    Recommendation: To further standardize administrative research requirements, the Secretary of Energy, the NASA Administrator, the Secretary of Health and Human Services, and the Director of NSF should coordinate through Office of Science and Technology Policy's (OSTP) Research Business Models working group to identify additional areas where they can standardize requirements and report on these efforts.

    Agency Affected: National Science Foundation

 

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