A great goal, I think everyone would agree. This is the focus of the Federal Demonstration Partnership sponsored by the National Academy of Sciences. For educational institutions, many of the relevant rules are codified in OMB Circular A-21, Cost Principles for Educational Institutions, OMB Circular A-110 , Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations, OMB Circular A-122 , Cost Principles for Non-Profit Organizations, and OMB Circular A-133 Audits of States, Local Governments, and Non-Profit Organizations.
The Research Business Models Subcommittee (RBM), a subcommittee of the Committee on Science chartered by the National Science and Technology Council (NSTC) is charged with “facilitating a coordinated effort across Federal agencies to address important policy implications arising from the changing nature of scientific research, and examining the effects of these changes on business models for the conduct of scientific research sponsored by the Federal government.”
The RBM is responsible for, among other initiatives, the development of the Research Performance Progress Report (RPPR), which is being implemented currently by agencies sponsoring research grants. The RBM includes an inter-agency task force focused on A-21, which last week released a request for information regarding revisions to A-21. (Responses to this request for information can be submitted via this website through July 28, 2011).
Based on preliminary task force work, potential areas of improvement include: Effort reporting; recovery of direct costs for administrative support for investigators; broader eligibility across institutions for the Utility Cost Adjustment; consistency in the development of F&A rates as well as application of approved rates across agencies. A fuller list is provided in the NIH Guide notice . Of particular note, this effort does not include consideration of the 26% administrative cost cap nor does it apply to compliance issues associated with non-profits, hospitals and for-profits, which do not fall under A-21.
These are interesting times as concomitant with this exercise to review burden associated with A-21, we also note the ongoing developments with the Digital Accountability and Transparency Act of 2011 (DATA Act) and the President’s executive order on Delivering an Efficient, Effective, and Accountable Government published on the same day the DATA Act was submitted. The DATA Act builds on the achievements of the Recovery Accountability and Transparency Board creating a successor, to be known as the Federal Accountability and Spending Transparency Board. The DATA Act if enacted is expected to codify many of the agency and institutional reporting requirements associated with stimulus funding on an ongoing basis.