Comment from June 10 Data Act Summit breakout session on Recipient Reporting:
There needs to be alignment of Federal Spending elements and the elements in the CDERL and elements like entity classification
2. Eliminate Two Layer IRB and IACUC Review of Human and Vertebrate Animal Research - Institutions receiving federal funds for research with human subjects or vertebrate animals are required to maintain a Federal-wide Assurance (FWA) or Animal Welfare Assurance (AWA) with the DHHS Office of Human Research Protections (OHRP) or Office of Laboratory Animal Welfare (OLAW), respectively. Institutions thereby accept the responsibility ...more »
The FAR requires semi-annual submission of Individual Subcontract Reports (ISRs) for all federal agencies, as well as Summary Subcontract Reports (SSRs) for DoD and NASA, and annual submission of SSRs for civilian agencies. In addition to the submissions required during performance of a covered contract, ISRs are required to be submitted within 30 days of contract completion. Amending the FAR, at a minimum, and the ...more »
Based on the lack of any perceptible value for the agencies or the public, we recommend that Congress repeal the mandate for reporting on executive compensation and that the FAR Council subsequently revise the relevant contract clauses. Doing so will save millions of dollars and liberate additional contractor and government resources to focus on what matters most—achieving the missions of the federal government and serving ...more »
In at least some areas of NSF there is a two-stage proposal process: A short preliminary proposal goes to an initial screening. If it passes that initial screening then a full proposal must be written. I would propose that NEH adopt this process as well. Given the intense competition for NEH grants, with a success rate hovering around 15%, although for the most competitive grants it’s about 6%. Writing grants is a ...more »
The Federal Acquisition Regulation (FAR) requires federal service contractors to report their direct labor hours and amounts invoiced to the government. This mandate is intended to help federal agencies fulfill their annual requirement to submit to the Office of Management and Budget (OMB) an inventory of activities performed by service contractors, in order to help determine whether agencies have the right balance of ...more »
Last year, the Coalition for Government Procurement submitted a number of recommendations in response to the Chief Acquisition Officers Council (CAO) Council Open Dialogue to improve the economy and efficiency of the Federal acquisition system. The Coalition urges the government to take action on the previously submitted recommendations to increase the efficiency and the effectiveness of Federal procurement. Implementing ...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 »
Comment from June 10 Data Act Summit breakout session on Recipient Reporting:
As a Federal Award recipient, I want to easily correct errors I find in government data systems. I want to be able to alert the contracting office, for them to quickly make a correction, for this process to be seamless.
Currently Modified Total Direct Cost (MTDC) only allows inclusion of subcontracts up to the first $25,000 of each subaward or subcontract (regardless of the period of performance of the subawards and subcontracts under the award). We suggest increasing this to the first $50,000.
I am surprised more people haven't been commenting or making suggestions. Do you think it might be due to the fact that most of us are so busy with our jobs, lacking funds, burnt out and trying to pick up pieces of pie because we are spending our own time working and ignoring everything else? Our jobs have become so complicated with reporting and regulations that we don't have time to take care of the people and partners ...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.