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: 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: Closed - Not Implemented

    Comments: As of August 2020, HHS had considered certain actions to address this recommendation but had not provided information on agency-specific actions it took to implement the recommendation. In particular, HHS engaged in interagency discussions that provided opportunities to share strategies to reduce pre-award requirements. HHS also considered but did not provide information on its implementation of (1) reductions in 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, or (2) pilot programs to streamline the grant application process. Therefore, GAO is no longer assessing implementation of this recommendation.

    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: Closed - Not Implemented

    Comments: As of August 2020, HHS had considered certain actions to address this recommendation but had not provided information on actions it took to implement the recommendation. In particular, HHS did not provide information on steps to follow through with plans it had in July 2018 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. Therefore, GAO is no longer assessing implementation of this recommendation.

    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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