Suggestions on how the benefits of the Performance Measures could be enhanced and the burdens of reporting could be reduced.
*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?
Since the implementation of the PHS requirements for disclosure of potential financial conflicts of interest for all key personnel at the time of proposal, this has been one of the most burdensome requirements for Faculty and staff at the University of Chicago. Last year alone we were required to obtain over 5,000 disclosures of financial interests before PHS proposals could be submitted, while only 115 of those disclosures ...more »
There is much redundancy in the current reporting. Suggest the following: 1) one annual Progress Report 2) Performance Measure surveys ONLY to be done ONCE in the 3 year grant period 3) when submitting renewal grants if the workplans are not changes have a box to simply check that off. 4) same for budgets 5) Accessability and Site Safety checks only to be done ONCE in the 3 year grant period and reflected in the MOU. ...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 »
Princeton University submits that the Uniform Guidance benefits higher education institutions in many ways, but only so long as the federal awarding agencies interpret the rules of the Uniform Guidance consistently. The following captures a few areas where consistency is needed: A. Sections 200.203(a)(5), Notice of funding opportunities (CFDA Numbers), and 200.301, Performance measurement – neither of these sections ...more »
If a centralized reporting database could be developed that all federal agencies, grantees, subrecipients, etc. would be required to use for reporting, and it would prepopulate many of the fields once the entity enters their FAIN, this would ease a lot of the reporting burden.
However, first, the FAIN would have to start being included in grant agreements so entities have that piece of information to enter.
Change UG to Allow 120 Days for all Final Reporting (Financial and Programmatic) for all agencies Currently the Uniform Guidance (UG) requires that all financial & programmatic reports are submitted to the sponsor within 90 days after end date. Several agencies, through coordination with the FDP (Federal Demonstration Partnership) and COGR, are adjusting their deadlines to 120 days after end-date. These agencies, most ...more »
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 ...more »
Limit the public release of federal audit reports until they have been validated through audit resolution. Since universities are reputation-based organizations, great harm can result from premature release of audit reports that are later found to be out of step with agency policy. In addition, and as a result of some universities efforts to be 100% compliant, premature release of audit reports can result in the enactment ...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 »
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 »
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.