Recommendation: The Under Secretary for Health should ensure VA's key offices, such as OAA and ORD, provide VA medical centers with examples of successful practices for strengthening research relationships with academic affiliates and that such information reflects the lessons learned from VA medical centers that have successfully cultivated these relationships. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation. VA stated that they will establish a working group with representatives from both VA's Central Office and the field to identify and share best practices by December 31, 2020.

Recommendation: The Under Secretary for Health should ensure ORD, in consultation with the field, develops tools, such as a decision tree and successful practices, to help local VA medical center officials decide which entity—NPCs or academic affiliates—should administer extramural funding based on providing optimal support for the research. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation. VA stated that the working group established to address GAO's first recommendation, which will include representatives from both VA's Central Office and the field, will develop and share tools to assist VA medical centers and their academic affiliates in determining how federal awards should be administered by December 31, 2020.

Recommendation: As NIH-DFAS begins formalizing its internal guidance, the Director of NIH-DFAS should establish a mechanism for tracking key milestones in the indirect cost rate-setting process, such as when indirect cost rate proposals are due.

Agency: Department of Health and Human Services: Public Health Service: National Institutes of Health: Office of Management: Office of Acquisition and Logistics Management: Office of Acquisition Management and Policy: Division of Financial Advisory Services
Status: Open

Comments: HHS concurred with this recommendations. In response, HHS stated that National Institute of Health's Division of Financial Advisory Services (DFAS) will establish a mechanism for tracking key milestones in the indirect cost rate-setting process. NIH-DFAS has initiatives underway that include moving from paper to electronic submissions of indirect cost proposals and developing a replacement to its Commercial Rate Agreement Distribution Services website. DFAS is looking into the feasibility of incorporating key milestones into these two major initiatives. NIH-DFAS is currently working with a contractor to develop a web based system that will establish a tracking system to account for when indirect cost proposal are due from organizations. The original initiative to enable the electronic submission of indirect cost proposals was modified to incorporate this new requirement. NIH-DFAS anticipates the planned date for implementation of this system to be October 1, 2017. As of February 4, 2020, this recommendation is still open because DFAS does not have the "proposal due date" and "extension due date" data fields activated in eFLow. DFAS is looking into adding those enhancements and hope to have these updates implemented by June 30, 2020. On July 8th, 2020, NIH-DFAS notified us that they plan to update us with the status of this recommendation by October 2020. We will continue to monitor the status of this recommendation.

Recommendation: In order to ensure complete, analyzable records regarding research grant award decisions are available for management and analysis, the Secretary of Energy should direct DOE's grant-making agencies to implement additional data collection efforts, which should include: (1) Retaining complete records of pre-proposal, proposal, and award data, including a record of proposal disposition, in linked electronic files to facilitate aggregate, statistical analysis of the grant-making process, including the calculation of success rates. (2) Collecting demographic, education, and career information from applicants, on a voluntary basis, that is not available to proposal reviewers but is used for analysis of success rates.

Agency: Department of Energy
Status: Open

Comments: DOE generally agreed with this recommendation. DOE's Office of Science began collecting investigator demographics during the second quarter of fiscal year 2015 and already retained complete records that enabled the calculation of success rates. According to DOE officials, since September 2017, the other three grant-making components included in our audit have been taking various actions to implement the recommendation. These three components, the Office of Nuclear Energy (NE), the Advanced Research Projects Agency-Energy (ARPA-E), and the Office of Energy Efficiency and Renewable Energy (EERE), all complete steps to ensure that they retain complete grant life cycle information for each individual award, including complete records of pre-proposal, proposal, and award data in linked electronic files, thus fulfilling the first part of our recommendation. In 2019, EERE coordinated the development of a Federal Register Notice (FRN) regarding data collection jointly with NE and ARPA-E. The FRN drafted by EERE was finalized and published on February 11, 2020 (Vol. 85, Issue 28, Pages 7759-7760 [FR DOC# 2020-02674]). Under the proposed information collection request, an interface will be implemented in DOE grant application systems to allow external users to voluntarily provide a minimal amount of demographic information to comply with this recommendation, pursuant to review by the Office of Management and Budget. On June 30th, DOE officials shared with GAO the draft FRN for the 30-day notice and request for public comment prior to implementation.

Recommendation: To comply with Title IX enforcement requirements, the Secretary of the Department of Defense, which funds STEM research at universities, should direct the Director of the Office of Diversity Management and Equal Opportunity to ensure that Title IX compliance reviews of DOD's grantees are periodically conducted.

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation and noted it is in the process of revising current DOD guidance which will address its Title IX enforcement requirements. In September 2017, a DOD official stated that the agency is in the process of formulating instructions related to both Title IX and Title VI that they believe will address the recommendation regarding Title IX enforcement. In a memorandum issued in December 2017, a DOD official described the agency's corrective action plan (CAP), including drafting an updated rule for the Code of Federal Regulations and the development and issuance of internal DOD policy documents regarding Title IX enforcement requirements. Both of these activities were expected to be completed by June 2019. DOD reported in March 2020 that it is continuing to revise current DOD guidance to address its Title IX enforcement requirements. The Director of DOD's Office of Diversity, Equity, and Inclusion (ODEI) stated in a letter to GAO that the revised Titile IX policy is in the early stages of DOD's policy process. ODEI expressed its commitment to developing the revised policy and ensuring Title IX compliance reviews are conducted as per the revised policy and GAO's recommendation. In September of 2020, DoD sent an update indicating that they will issue a policy memorandum, specifically outlining the requirement for DoD Components who provide financial assistance to educational programs or activities conduct periodic compliance reviews. This is expected to be complete by December 31, 2020.

Recommendation: To help address the uncertainty NIH faces, related to the potential impact of increasing indirect costs on its funding of future research, the Director of NIH should assess the impact of growth in indirect costs on its research mission, including, as necessary, planning for how to deal with potential future increases in indirect costs that could limit the amount of funding available for total research, including the direct costs of research projects.

Agency: Department of Health and Human Services: Public Health Service: National Institutes of Health
Status: Open

Comments: As of July 7, 2015, NIH provided some information indicating that it had taken action to address our recommendation by tracking the size of indirect costs as a proportion of NIH's overall budget as part of the agency's annual budget planning process and risk assessment program. However, we determined that the actions did not fully address the recommendation because they focus on the agency's overall budget and do not assess the potential ongoing impact of indirect costs for universities on its mission. As of September 2018, NIH officials have not informed us of any additional actions taken to implement this recommendation. We will update the status of this recommendation when we receive additional information.