TRADITION VS THE COHORT
Several reports support the Federal Demonstration Partnership surveys (2005 and 2012) of principal investigators (PIs) of federally funded research projects that found PIs spend, on average, 42% of their research time on administrative tasks. This administrative workload is negatively affecting the conduct of science and is disproportionate to the goal of accountability and transparency in managing federal funds. Duplicative reporting of data is rampant, and despite the intent of the regulatory changes introduced by Uniform Guidance (UG), federal funding agencies, as well as recipients of federal funds, continue to struggle with consistent interpretation of issued policies and guidance.
The federal government invested more than $140 billion dollars in research and development activities in 2016 (AAAS). Historically, efforts have been made by the federal government to standardize and harmonize business processes and policies across the grant making agencies with limited success.
However, a one-size fits all mandate is unrealistic and would most certainly have a catastrophic impact on the creativity and flexibility needed to fund and manage federally sponsored research projects. The goal is to strike a balance and eliminate the non-value-added activities, harmonize business processes and create consistent policy implementation and interpretation for all stakeholders: the federal grant making agencies, the award recipients and the audit community.
There is sometimes a significant disconnect between policy and guidance at the proposal submission stage of an award life cycle and the policy and guidance on how to manage the project once awarded. These variances with the same agency, and across agencies, as well as the award recipient’s own interpretation of policy and guidance, contributes significantly to wasted resources for both entities and can result in significant audit findings for award recipients. Most importantly, these administrative requirements have little or nothing to do with the performance of the research, and oftentimes, can hinder scientific progress. The current model of proposal submission and award management for federal projects forces both entities to focus on issues that do not maximize the scientific return on investment.
Effort reporting has long been pointed to as an example of administrative burden for award recipients (both the institution and for faculty who are forced to engage in the process). Effort reporting was included in government Circular A-21, Cost Principles for Educational Institutions as an example of how award recipients could satisfy the after-the-fact review requirement for the portion of ‘time’ spent on an activity. Many institutions of higher education invested millions of dollars to meet an implied requirement (effort reporting was only an example) that does not fit with their business model. Faculty researchers are not hourly employees and do not track ‘time’, i.e., hours spent on their scholarly activities (most commonly teaching, service and research). Several major universities (Northwestern University, University of Southern Florida, Yale University, Johns Hopkins, Harvard University, and University of Alabama Birmingham are a few examples) have been assessed very large penalties and/or settlements due in large part to effort reporting violations.
Salaries and wages normally comprise a significant amount of a project budget so it is understandable why these charges would require additional scrutiny from the audit community. However, the amount of salary charged to a project and the amount of ‘time’ a researcher spent working on the project do not always have a 1:1 correlation.
Duplicative data reporting across agencies for both proposals and awards is another example of organizational waste caused by a lack of standardization across federal grant making agencies. The data needed for this analysis is also publicly available from agency published proposal submission and award management guidance and policy.
Financial reporting is another example of duplicative data reporting. Many federal agencies allow award recipients to draw down reimbursement for expenses from their payment system. The reimbursement request includes project specific expense information. Despite this level of financial detail being submitted in order to receive reimbursement, award recipients are also required by some agencies to submit the Federal Cash Transaction report on a quarterly basis that summarizes their reimbursement request activity. In addition, award recipients are required to submit an interim (quarterly, semi-annual, annual, etc.) project specific Financial Status Report as well as a final Financial Status Report.