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: OMB did not comment on this recommendation and, as of February 2019, had not provided information on steps it has taken to implement this recommendation. However, the President's Management Agenda, released in March 2018, states that federal agencies will maximize the value of grant funding by applying a risk-based, data-driven framework that balances compliance requirements with demonstrating successful results. We will continue to monitor OMB'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 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 December 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 December 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 December 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 December 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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