AAU, COGR and APLU recommend that agencies eliminate quarterly financial reports once they have transitioned to subaccounts. Institutions draw down cash by award accounts on a regular basis, typically monthly. This provides agencies with up-to-date financial information and renders additional financial reports unnecessary. Agencies should also consider whether there is a need for annual and final financial reports and ...more »
AAU, COGR and APLU recommend a common federal portal for grants submission, invoicing/cash draw downs, and final reporting (e.g., progress, financial, equipment) with a single set of rules, forms and due dates (potentially using NSF policy and guidelines as a model). A common portal would significantly ease reporting burden. - Consolidate federal proposal and award management systems, including payment systems, optimally ...more »
AAU, COGR and APLU recommend that OMB clarify that where a subrecipient has a current Single Audit report, prime recipients can rely on the subrecipient’s auditors and cognizant agency oversight for routine audit follow-up and management decisions. Science is engendering an increased number of collaborative projects, resulting in significant growth in the number of subawards issued and received by institutions of higher ...more »
AAU, COGR and APLU recommend that OMB raise the micropurchase threshold from $3,000 to $10,000 to reflect current practices. As data supports a higher threshold, OMB should consider future adjustments. The UG has introduced a category known as “Micro-Purchases,” defined as purchase transactions up to $3,000, below which there is no requirement to document competition. This was not included in the proposed guidance so ...more »
AAU, COGR and APLU recommend that OMB require Federal agencies to adopt common research terms and conditions. We believe NSF, NIH, USDA NIFA, NIST, NOAA, DOE, FAA, EPA and NASA are creating common RTCs, but other agencies have opted out. Clear and consistent data definitions are also needed. Not all federal agencies are signing on to federal-wide research terms and conditions for federal awards under the Uniform Guidance ...more »