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Highlights

GAO reported on the Association of American Universities and the National Science Foundation (NSF) experiment in research grant administration which focuses on the needs of universities for flexibility in allocating funds while ensuring appropriate financial accountability.

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Recommendations

Recommendations for Executive Action

Agency Affected Recommendation Status
National Science Foundation 1. The Director of NSF should require that NSF review each university's OPAS to ensure that the university has established a system that can act responsibly before any delegations of prior approval authorities are made.
Closed - Not Implemented
On April 1, 1983, NSF opened this system to all grantee institutions. NSF sent out standards for the university OPAS systems to follow. There are now about 700 institutions with such systems, far too many for NSF to monitor. The review is based on institutional self-certification and NSF spot checks through site visits.
National Science Foundation 2. The Director of NSF should ensure that applicable NSF regulations or grant agreements explicitly provide that the authority to approve preaward costs cannot impose an obligation on the United States prior to the availability of appropriations.
Closed - Implemented
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
National Science Foundation 3. The Director of NSF should closely monitor the universities' use of the experiment's authorities and provide those responsible for managing the experiment at the universities with information on changes or modifications to the experiment in a timely manner.
Closed - Not Implemented
As of April 1983, the process was no longer an experiment. Insitutions are regulary advised of changes through normal updates of the grant policy manual and important notices distributed, as with all NSF policies and procedures.
National Science Foundation 4. The Director of NSF should require that each university's OPAS have an official independent of the participating departments who can ensure that each department is exercising the delegated authorities properly and who has or has available the scientific expertise necessary to review and approve actions.
Closed - Implemented
The NSF evaluation panel did not believe this to be necessary; it thought that it was too burdensome for an individual outside of NSF to be involved. Therefore, NSF has not required that this recommendation be implemented.
National Science Foundation 5. The Director of NSF should require that all OPAS actions document: (1) the description of the request; (2) the scientific reason for the request; and (3) the source of the funds being rebudgeted and for rebudgeting actions on grants with special grant conditions.
Closed - Implemented
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
National Science Foundation 6. The Director of NSF should require that: (1) each university report to the cognizant NSF official all OPAS actions on any grant whenever the cumulative OPAS actions, excluding preaward costs, exceed 25 percent of the grant's direct costs; and (2) NSF ensure that each participating university is aware that its OPAS is responsible for monitoring all actions on grants with special grant conditions.
Closed - Implemented
NSF does not like the requirement of a fixed percent threshold. NSF officials monitor the universities through spot checks. It is already the universities' responsibility to monitor actions on special grant conditions. Therefore, it is up to each university, not NSF, to decide whether to delegate this responsibility to its OPAS.
National Science Foundation 7. The Director of NSF should require that retroactive approvals of actions needing prior approval: (1) document the reasons why prior approval was not obtained in a timely manner; and (2) certify that approval would have been given had the request been submitted on time.
Closed - Implemented
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
National Science Foundation 8. The Director of NSF should develop a Phase II evaluation plan and ensure that the necessary resources are available to carry it out. The evaluation should include a thorough review of each university's OPAS policies, procedures, and actions, and be conducted by official(s) independent of those managing the experiment.
Closed - Implemented
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

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