Harmonize Agency Public Access Procedures and Submission

AAU, COGR, and APLU recommend that OMB require all Federal agencies subject to OSTP’s 2013 policy memorandum, “Increasing Access to the Results of Federally Funded Scientific Research,” to harmonize the procedures by which extramural grantees submit final peer-reviewed manuscripts or final published documents and data to the agencies’ public access repositories. We believe that this harmonization process may most effectively be accomplished under the auspices of the National Science and Technology Council (NSTC).

A multiplicity of divergent public access policies will substantially increase the administrative burden on grantees as they will be required to comply with an array of different terms and conditions across multiple funding agencies. Accordingly, we urge the creation of a single governmental portal through which federal grantees can submit their final peer-reviewed manuscripts or final published documents and data via a uniform compliance procedure to all funding agencies. Alternatively, but less optimally, we would propose that all funding agencies be required to seamlessly and non-redundantly integrate their public access submission requirements into their existing progress reporting procedures.

We also suggest that every federal funding agency include in its public access policy an “opportunity to cure” provision that would afford grantees with proven compliance track records a reasonable grace period within which to correct any errors or omissions relating to their public access submissions before any funding under the applicable grant is suspended or terminated or any other punitive measures are applied. If a given agency conditions the continuation of funding on prompt public access compliance, this grace period should also permit funding to continue where the grantees’ timely compliance is hindered by technical difficulties at the agency level.

We have already heard from grantee universities that have incurred costly delays in NIH funding due to minor and/or inadvertent errors in their submissions to NIH’s PubMed Central or due to technical challenges uploading materials to PubMed Central that are beyond the control of the universities or investigators involved. These costs are not only financial; they also impede the forward momentum of the research and science being pursued under the grants. Thus we believe there must be mechanisms in public access policies to ensure that funding streams are not interrupted – to the detriment of both grantees and funding agencies – by readily remediable submission mistakes or technical obstacles at the agency level.

reporting-processes

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Contractors and Grantees
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Reporting compliance requirements shared by prime and subawardees of Federal procurements and grants
Key Participants: contractors, grantees, cooperative agreement holders, and subawardees
- Question: If you could change one thing that would ease your reporting burden associated with your awards, what would it be (e.g. time, cost, resource, other)?
- Question: If you have reporting requirements to the Federal government, how are those met?
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities or functions would you include?
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Contractors
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Procurement practices, processes, and reporting
Key Participants: Contractors and subcontractors
- Question: If you could change one thing that would ease your reporting burden associated with your awards, what would it be (e.g. time, cost, resource, other)?
- Question: If you have reporting requirements to the Federal government, how are those met?
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities or functions would you include?
- Question: Are there any reporting areas in the FAR that are similar in nature to those in Federal agency supplements?
- Question: What other compliance information are you providing to the Federal government outside of the procurement process that could be used in procurement reporting and reduce duplication?
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Grantees
*To participate in the dialogue, you can submit a new idea by clicking "Submit New Idea" to the right, or you can vote and comment on existing ideas below.

Grants practices and processes
Key Participants: grantees, cooperative agreement holders, subgrantees
- Question: If you could change one thing that would ease your reporting burden associated with your grants or subgrants, what would it be (e.g., time, cost, resource burden)?
- Question: If you have reporting requirements to the Federal government, how are those met? (feel free to be specific about what is reported to whom and through what mechanism)
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities/functions would you include?
OMB circular A-133:
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditee?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditor?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting to the Federal Audit Clearinghouse?
Uniform Guidance (2 CFR 200):
- Question: Are there requirements in the new 2 CFR 200 that need additional clarification for improved implementation with reduced administrative burden ?
- Question: What are the perceived burdens associated with the new standards such as the documentation of salaries & wages and time & effort (2 CFR 200.430), subrecipient monitoring (2 CFR 200.331), procurement standards (2 CFR 200.317- 2 CFR 200.324)?
- Question: How can the administrative burden associated with standards compliance be lowered?
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