Recommendations for Executive Action

1. Status: Closed - Implemented

   Comments: According to DOE officials, the agency established an interdisciplinary team to conduct an agency-wide review of the terms and conditions for its funding opportunity announcements and finalized revisions to the terms and conditions in 2018. DOE officials stated that the objective of the review was to identify opportunities to improve consistency across the department to reduce administrative burdens for potential applicants. The officials stated that as a result of this review, DOE increased applicants' use of concept papers and pre-applications as a way to save applicants' time and expense in preparing a complete application that may be unlikely to be selected for award. In addition, DOE engaged in interagency discussions that provided opportunities to share strategies to reduce pre-award requirements, including through OSTP's Research Business Models working group. For example, the group has considered developing a centralized system for grant applicants to provide assurances of their compliance with various federal requirements.

   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: As of January 2020, HHS had engaged in interagency discussions that provided opportunities to share strategies to reduce pre-award requirements, including through OSTP's Research Business Models working group. For example, the group has considered developing a centralized system for grant applicants to provide assurances of their compliance with various federal requirements. However, HHS had not provided information on any agency-specific actions it has taken to address this recommendation. In 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. We will continue to monitor the department's efforts and provide updated information when it becomes available.

   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: Closed - Implemented

   Comments: In an August 2019 update to its internal policy guidance for awarding and administering grants and cooperative agreements, NASA introduced a two-step proposal process to reduce administrative burden during the proposal submission process. In this process, prospective applicants submit an abbreviated presentation of the intended research prior to a full proposal. According to the manual, the inclusion of this two-step process postpones certain elements of an application, such as detailed budgets, until a preliminary decision is made about an applicant's likelihood of funding. In addition, NASA engaged in interagency discussions that provided opportunities to share strategies to reduce pre-award requirements, including through OSTP's Research Business Models working group. For example, the group has considered developing a centralized system for grant applicants to provide assurances of their compliance with various federal requirements.

   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: As of January 2020, HHS had not provided information on actions it took to address this recommendation. In July 2018, HHS officials stated that 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 interest. We will continue to monitor the department's efforts and provide updated information when it becomes available.

   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: Closed - Implemented

   Priority recommendation

   Comments: OMB engaged in several efforts to address this recommendation. Under the President's Management Agenda released in March 2018, OMB committed to reducing grant recipients' time on administrative compliance by applying a risk-based framework to grant funding. In keeping with this goal, OMB participated in the interagency Research Business Models working group's efforts to reduce administrative burdens on federally funded researchers. In a May 2018 report, the working group stated that it would investigate factors that have kept grant recipients from applying a risk-based approach to subrecipient monitoring. In addition, to allow flexibility for grant recipients, in June 2018 OMB granted an exception allowing recipients to use higher purchase thresholds in advance of revisions to the Federal Acquisition Regulation and Uniform Guidance.

   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: Closed - Implemented

   Comments: As of February 2020, DOE, HHS, NASA, and NSF participated in several interagency efforts to identify areas for standardizing administrative requirements for federal research grants. In coordination with OMB and OSTP, the agencies participated in efforts of the Research Business Models Working Group to reduce administrative burdens on federally funded researchers. In May 2018, the Working Group issued a report identifying two potential areas for standardization or harmonization of requirements, such as the policy for what constitutes a financial conflict of interest. Moreover, the agencies participated with OSTP in efforts of the Joint Committee on the Research Environment, established in May 2019 to address challenges facing the research and scientific community. In November 2019, OSTP on behalf of the committee issued a request for information seeking comment on actions the federal government can take to reduce administrative work associated with financial conflict of interest requirements. The request asked about, among other things, the potential benefits and challenges of a streamlined, harmonized, federal-wide policy. Also in November 2019, the White House convened representatives from industry, academia and the federal government to discuss the committee's progress and ways to decrease the workload of complying with administrative requirements for research, such as by establishing common forms and systems across funding agencies.

   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: Closed - Implemented

   Priority recommendation

   Comments: As of February 2020, DOE, HHS, NASA, and NSF participated in several interagency efforts to identify areas for standardizing administrative requirements for federal research grants. In coordination with OMB and OSTP, the agencies participated in efforts of the Research Business Models Working Group to reduce administrative burdens on federally funded researchers. In May 2018, the Working Group issued a report identifying two potential areas for standardization or harmonization of requirements, such as the policy for what constitutes a financial conflict of interest. Moreover, the agencies participated with OSTP in efforts of the Joint Committee on the Research Environment, established in May 2019 to address challenges facing the research and scientific community. In November 2019, OSTP on behalf of the committee issued a request for information seeking comment on actions the federal government can take to reduce administrative work associated with financial conflict of interest requirements. The request asked about, among other things, the potential benefits and challenges of a streamlined, harmonized, federal-wide policy. Also in November 2019, the White House convened representatives from industry, academia and the federal government to discuss the committee's progress and ways to decrease the workload of complying with administrative requirements for research, such as by establishing common forms and systems across funding agencies.

   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: Closed - Implemented

   Priority recommendation

   Comments: As of February 2020, DOE, HHS, NASA, and NSF participated in several interagency efforts to identify areas for standardizing administrative requirements for federal research grants. In coordination with OMB and OSTP, the agencies participated in efforts of the Research Business Models Working Group to reduce administrative burdens on federally funded researchers. In May 2018, the Working Group issued a report identifying two potential areas for standardization or harmonization of requirements, such as the policy for what constitutes a financial conflict of interest. Moreover, the agencies participated with OSTP in efforts of the Joint Committee on the Research Environment, established in May 2019 to address challenges facing the research and scientific community. In November 2019, OSTP on behalf of the committee issued a request for information seeking comment on actions the federal government can take to reduce administrative work associated with financial conflict of interest requirements. The request asked about, among other things, the potential benefits and challenges of a streamlined, harmonized, federal-wide policy. Also in November 2019, the White House convened representatives from industry, academia and the federal government to discuss the committee's progress and ways to decrease the workload of complying with administrative requirements for research, such as by establishing common forms and systems across funding agencies.

   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: Closed - Implemented

   Comments: As of February 2020, DOE, HHS, NASA, and NSF participated in several interagency efforts to identify areas for standardizing administrative requirements for federal research grants. In coordination with OMB and OSTP, the agencies participated in efforts of the Research Business Models Working Group to reduce administrative burdens on federally funded researchers. In May 2018, the Working Group issued a report identifying two potential areas for standardization or harmonization of requirements, such as the policy for what constitutes a financial conflict of interest. Moreover, the agencies participated with OSTP in efforts of the Joint Committee on the Research Environment, established in May 2019 to address challenges facing the research and scientific community. In November 2019, OSTP on behalf of the committee issued a request for information seeking comment on actions the federal government can take to reduce administrative work associated with financial conflict of interest requirements. The request asked about, among other things, the potential benefits and challenges of a streamlined, harmonized, federal-wide policy. Also in November 2019, the White House convened representatives from industry, academia and the federal government to discuss the committee's progress and ways to decrease the workload of complying with administrative requirements for research, such as by establishing common forms and systems across funding agencies.

   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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