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Council on Governmental Relations (COGR): Update on Recovery Act-Direct Charging, Grants.gov, and Regulatory Reform

Meeting with Federal Officials to Discuss Direct Charging of Research Administration Specialists on Recovery Act Grants

On Monday, March 16, COGR representatives met with Gilbert Tran from OMB and 20 other individuals representing a diverse group of Federal entities to discuss COGR’s proposal to permit Research Specialist personnel to be direct charged to Recovery Act awards. Included were representatives from NIH, NSF, DOD, ONR, DCA, and OMB Budget Specialists. Joanne DeStefano from Cornell and Jim Luther from Duke accompanied David Kennedy and Tony DeCrappeo from the COGR staff to present the university perspective.

The meeting was in response to COGR's February 27 letter to the OMB Director, Peter Orszag, urging OMB to allow direct charging of such personnel due to the extraordinary reporting requirements for Recovery Act awards. While there were some challenging questions by several of the Federal representatives, overall their reaction was positive.

Next steps are:

A core group of those attending the meeting will further discuss,; we expect to hear back in 3 to 4 weeks.
Any guidance will be provided in the form of an OMB FAQ-type document.
If the proposal is accepted, the key compliance requirement will likely be that Research Specialist personnel can be charged to Recovery Act awards only.
Research Specialist personnel will need to complete effort reports and show on an award-by-award basis that the effort was provided.
It is likely that Federal and A-133 auditors will look closely at these effort reports, and from a Federal perspective, will be an audit focus area.

Grants.gov Developments

On Thurs., March 12, Ara Tahmassian from Boston University and RCA Committee Chair, and Carol Blum of the COGR staff met with Government Accountability Office (GAO) staff to discuss on-going problems with Grants.gov. GAO is in the midst of preparing a report in response to a Congressional inquiry about the implementation of Grants.gov as a streamlining initiative under the Federal Financial Assistance Management Improvement Act of 1999 (PL 106-107). The GAO report, expected in early spring, is focused on current problems with Grants.gov, as a system, and the agencies’ implementation and integration of Grants.gov into their application processes.

The discussion with GAO focused on three key questions: leadership; resources; and system design. The OMB Director is responsible for meeting the requirements of PL 106-107, including Grants.gov. The Director has created two interagency groups – the Grants Executive Board (GEB) and Grants Policy Committee (GPC) – to coordinate the design and implementation of the activities including the related policy developments. The GEB is responsible for implementation; the GPC for policy. In the case of Grants.gov, the Department of Health and Human Services (HHS) is the program manager. COGR believes this distributed leadership has not served to focus the development of Grants.gov on a system that effectively meets the needs of the various applicant communities. No single entity or individual has direct authority for ensuring the cooperation and collaboration of the agencies in the system design and deployment.

Grants.gov is funded through contributions or taxes on the agencies based on the total grant dollars awarded. PL 106-107 did not address the question of funding and resources for the implementation of the common application and reporting systems. The consequence of this funding model is insufficient staff to address program development and user support and a lack of sufficient capacity for the system to handle the volume of applications processed through Grants.gov.

COGR advocated for a change in Grants.gov from a forms-based system to a web-based system to streamline the application process. COGR questioned the wisdom of building the system on a commercial product, Adobe that continues to be developed and enhanced by the vendor. These changes and enhancements require continuous updates to local software or, as has been the case, a delay in local software updates to retain older versions of Adobe to ensure successful submissions.

As COGR prepared for the meeting with GAO, OMB Director Peter Orszag issued a memorandum to the Federal agencies requesting their cooperation in addressing the problems with Grants.gov in the face of the increased volume anticipated with applications in response to the American Recovery and Reinvestment Act of 2009 research initiatives. Orszag has asked HHS and the General Services Administration to make immediate improvements to accommodate the increased volume. He asked the federal agencies to identify alternatives to the use of Grants.gov to help alleviate the problem. Federal agencies with independent stand-alone systems will likely allow direct application, bypassing Grants.gov.

COGR recognizes the value of addressing these immediate problems but continues to pursue changes to affect long-term improvements. Read the joint COGR-AAU letter to the OMB Director expressing concerns and requesting a meeting.

COGR letter to OIRA on Improving the Regulatory Review Process

The Office for Information and Regulatory Affairs (OIRA) published a call for comments on improving the Government’s process for reviewing the impact of regulations proposed by federal agencies on the affected parties. The RCA Committee took this opportunity to respond, pointing out that non-profit colleges and universities suffer from the cumulative effect of many regulations that individually do not meet the current definition of a “major rule” that would require greater scrutiny, but that add up to a significant compliance burden, exacerbated by the administrative cap. Read the letter