Reporting and DATA Act Open Dialogue Ideas

Since the publication of the Uniform Guidance UG), institutions have seen various Conflict of Interest (COI) terms and conditions embedded within broad agency announcements and proposal solicitations, despite the lack of formal agency-wide policies or guidelines in most cases. The specific requirements for what financial interests and relationships need to be disclosed, the nature and timing of reviews, and even definitions ...more »

Research administrators work in a world of constant and continuous audits by various Federal OIGs. These are in addition to the ongoing annual "A-133" audits designed to attest to our having systems and procedures in place to provide proper stewardship over Federal funds under our purview. The OIG audits have been extremely aggressive and are characterized by initial allegations of wrongdoing, high cost disallowances, ...more »

Grant Proposals indicate all institutions involved and require separate budget submissions. Not only is it a waste of taxpayer $ to pay institutions F&A on the first 25K of each sub, but it is so inefficient to dole out the $ to us to turn around and pay out the subs when you can utilize a LOC payment system. Then you impose subrecipient monitoring on us and everybody has to document everyone else's audit report/FCOI ...more »

Princeton University suggests that the Federal Audit Clearinghouse (FAC) should provide more guidance (e.g. definitions, acronyms) on how to access and leverage annual reports to monitor subrecipients per Uniform Guidance requirements in order to reduce the burden. Assistance in navigating through the forms similar to guidance provided to comply with the Federal Funding Accountability and Transparency Act (FFATA) would ...more »

OMB should clarify the parameters for the risk analyses that universities are required to make for their subrecipients under the Uniform Guidance. Such a move would help to curtail the proliferation of individualized standards or action plans established by individual universities seeking to carry out their responsibilities under the as prime recipients with respect to their subrecipients.

Consider an effort to have PUBLIC LAW 96-511—DEC. 11, 1980 (Paper Reduction Act) updated or encourage a new public law so as to change the focus to reducing administrative burden (i.e. creation of a “Administrative Burden Reduction Act”). The goal would be to (1) engage the research community on an ongoing basis to create efficiencies, (2) encompass a risk analysis for all types of administrative activities to match ...more »

A single, central reporting portal for all reporting would help achieve the goals of the DATA Act. A central portal should provide the following functions: 1) One Portal a. The goal is to have one place for recipients to report on research expenditures. b. All the agencies conform from the beginning. i. If exceptions are granted, it should be clearly documented who has been granted an exception and, the length of time ...more »

Enactment of the Digital Accountability and Transparency Act in May, 2014 provides many opportunities for the Office of Management and Budget and the Department of Treasury to improve the public transparency of Federal spending while simultaneously reducing the overall reporting burden on both Principal Investigators and institutional Research Administrators. However, there are also many implementation scenarios that ...more »

Government understandably wants to data-mine progress reports. The loss of Fastlane reporting, with its PDF structure, in exchange for plain text/fillable fields in Research.gov, is an example of this. However, the reporting format in Research.gov is ridiculously time-consuming. It has generated an extreme, labor-intensive, administrative burden. Not one Principle Investigator I know wants anything to do with Research.gov, ...more »

1. Achieve a true single audit. IHEs are still subject to multiple audits of their individual programs and compliance processes, despite the Single Audit Act of 1984, OMB Circular A-133 and 2CFR-200 Uniform Guidance which mandate single audits for non-federal entities that receive federal funding. The University is subject to a major compliance audit, desk audits and program audits each year.

1. Achieve a true single audit. IHEs are still subject to multiple audits of their individual programs and compliance processes, despite the Single Audit Act of 1984, OMB Circular A-133 and 2CFR-200 Uniform Guidance which mandate single audits for non-federal entities that receive federal funding. The University is subject to a major compliance audit, desk audits and program audits each year.

Harmonize Requirements and Standardized Collection of Non-Financial Training Prior to Issuance of an Award - Non-Financial Investigator training requirements (e.g. Financial Conflict of Interest, Responsible Conduct of Research, Research with Human Subjects), are convoluted because acceptable subject matter and timelines for completion vary by agency. Non-financial training requirements should be harmonized to reduce ...more »