1). The requirements in the Uniform Guidance aim to protect against waste,  fraud, and abuse in various ways, as follows. Budgets. To meet documentation requirements for purchases  made with grant funds, grantees must maintain records detailing the  procurement history for all purchases. Selected Administrative Requirements in Agency- Specific Guidance Generally Focus on Promoting the Quality and Effectiveness of Federally Funded Research

Funding agencies have established administrative requirements—in  some cases, in response to directives from Congress and OSTP—to  promote the selection and development of qualified researchers, protect  against bias in the conduct of research, and improve access to research  results. Selected Universities Identified Common Factors That Add to Their Workload and Costs for Complying with Selected Administrative Requirements

Selected universities and stakeholder organizations identified common  factors that add to their administrative workload and costs for complying  with selected requirements: (1) variation in agencies’ implementation of  requirements, (2) detailed pre-award requirements for applicants to  develop and submit documentation for grant proposals, and (3) increased  prescriptiveness of certain requirements. Officials at four universities said they expect to hire staff to  handle the added workload resulting from an increased volume of  purchases subject to OMB’s revised purchasing competition and  documentation requirements. These efforts have  included (1) standardizing requirements across agencies, (2) streamlining  pre-award requirements, and (3) in some cases allowing universities  more flexibility to assess and manage risks for some requirements. Research Performance Progress Report. Such efforts could help ensure that agencies  do not miss opportunities to reduce universities’ administrative workload  and costs and to improve their oversight of funding and support of  research quality. Funding Agency Efforts to Reduce Pre-Award Administrative Workload and Costs by Postponing Proposal Requirements Have Not Been Extended to All Applicable Grants or Requirements

DOE, NASA, NIH, and NSF have made efforts to reduce pre-award  administrative workload and costs associated with proposal preparation  by postponing certain requirements until after a preliminary decision  about an applicant’s likelihood of funding. OMB and Funding Agency Efforts to Allow More Flexibility Have Not Addressed Some Requirements

OMB and funding agencies have made efforts, in accordance with federal  goals, to reduce administrative workload and costs by allowing  universities more flexibility to assess and manage risks related to certain  administrative requirements. Executive Order 13563 calls for agencies to  identify and consider regulatory approaches that reduce burdens and  maintain flexibility for the public. Under RBM’s 2008 standard terms and conditions  that implemented that guidance, DOE, NASA, NIH, and NSF waived  many requirements for recipients to obtain prior approvals for budget  revisions. To better target requirements on areas of greatest risk, while maintaining  accountability over grant funds,  the Secretary of Health and Human Services, as part of the planned  evaluation of the HHS regulation governing financial conflicts of  interest in NIH-funded research, should evaluate options for targeting  requirements on areas of greatest risk for researcher conflicts,  including adjusting the threshold and types of financial interests that  need to be disclosed and the timing of disclosures, and  the Director of OMB, as part of OMB’s planned evaluation of the  Uniform Guidance, should evaluate options for targeting requirements  for research grants to universities, including requirements for  purchases and subrecipient monitoring, on areas of greatest risk for  improper use of research funds. NSF and OMB did not comment on our recommendations. DOE, HHS, and NASA concurred with our first recommendation to  coordinate through RBM to identify additional areas where they can  standardize requirements. Appendix I: Objectives, Scope, and Methodology

This report examines (1) the sources and goals of selected research  grant requirements, (2) the factors that contribute to universities’  administrative workload and costs for complying with these requirements,  and (3) efforts the Office of Management and Budget (OMB) and  research funding agencies have made to reduce the administrative  workload and costs for complying with these requirements, and the  results of these efforts. To address these objectives, we selected four agencies that fund  research grants to universities and focused on nine categories of  requirements associated with these agencies’ research grants:
The four funding agencies were the Department of Energy (DOE),  National Aeronautics and Space Administration (NASA), National  Institutes of Health (NIH) within the Department of Health and Human  Services, and National Science Foundation (NSF). According to NSF data, these four agencies provided about  83 percent of federal funding for research at universities and colleges  in fiscal year 2015. To examine factors that contribute to universities’ administrative workload  and costs for complying with selected requirements, we selected a  nongeneralizable sample of six universities to conduct in-depth interviews  of officials regarding each of the nine categories of requirements in our  scope and to collect qualitative information on the types of administrative  workload and costs resulting from the requirements—such as  administrative staff costs, researcher time, and investments in systems  and processes.
Why GAO Did This Study

The federal government obligated over $27 billion for university research in fiscal year 2015, according to NSF. To allow for oversight of these funds, Congress and research funding agencies established administrative requirements that universities must comply with as part of grants they apply for and receive. University stakeholders have studied and raised concerns about the workload and costs to comply with the requirements.
GAO was asked to review research grant requirements and their administrative workloads and costs. This report examines (1) the sources and goals of selected requirements, (2) factors affecting universities' administrative workload and costs for complying with the requirements, and (3) efforts by OMB and research funding agencies to reduce the requirements' administrative workload and costs, and the results of these efforts. GAO selected and examined in detail nine areas of administrative requirements at DOE, NASA, NIH, and NSF, and interviewed administrative staff and researchers from six universities. GAO selected agencies and universities that ranged in the amount and type of research funding provided or received.

What GAO Found

Administrative requirements for federal research grants include (1) Office of Management and Budget (OMB) government-wide grant requirements for protecting against waste, fraud, and abuse of funds and (2) agency-specific requirements generally for promoting the quality and effectiveness of federally funded research. For example, OMB requires grantees to maintain records sufficient to detail the history of procurement for all purchases made with grant funds, and the Department of Energy (DOE), National Aeronautics and Space Administration (NASA), National Institutes of Health (NIH), and National Science Foundation (NSF) require applicants to develop and submit biographical sketches describing their professional accomplishments so agencies can consider researchers' qualifications when deciding which proposals to fund.
Officials from universities and stakeholder organizations GAO interviewed identified common factors that add to their administrative workload and costs for complying with selected requirements: (1) variation in agencies' implementation of requirements, (2) pre-award requirements for applicants to develop and submit detailed documentation for grant proposals, and (3) increased prescriptiveness of certain requirements. They said that these factors add to universities' workload and costs in various ways, such as by causing universities to invest in new electronic systems or in the hiring or training of staff. For example, university officials told GAO that new OMB requirements for purchases made with grant funds will result in added costs for hiring administrative staff to handle an increased volume of purchases that are subject to some form of competition.
OMB and research funding agencies have made continuing efforts to reduce universities' administrative workload and costs for complying with selected requirements, with limited results. These included efforts in three areas: (1) standardizing requirements across agencies; (2) postponing certain pre-award requirements until after making a preliminary decision about an applicant's likelihood of funding; and (3) in some cases, allowing universities more flexibility to assess and manage risks for some requirements. For example, funding agencies have developed a standard set of administrative terms and conditions for research grants and a standard form for research progress reports. Such efforts are in accordance with federal goals, such as those in a 2011 executive order that calls for agencies to harmonize regulations and consider regulatory approaches that reduce burdens and maintain flexibility. However, opportunities exist in each of the three areas to further reduce universities' administrative workload and costs. First, efforts to standardize requirements have not fully addressed variations in agency implementation of requirements, such as agencies' forms and systems for collecting project budgets and biographical sketches. Second, funding agencies have not fully examined pre-award requirements to identify those—such as requirements for detailed budgets—that can be postponed. Third, some requirements—such as those for obtaining multiple quotations for small purchases—limit universities' flexibility to allocate administrative resources toward oversight of areas at greatest risk of improper use of research funds. Further efforts to standardize requirements, postpone pre-award requirements, and allow more flexibility for universities could help ensure agencies do not miss opportunities to reduce administrative workload and costs.

What GAO Recommends

GAO recommends that OMB, DOE, NASA, NIH, and NSF identify additional areas where requirements, such as those for budgets or purchases, can be standardized, postponed, or made more flexible, while maintaining oversight of federal funds. DOE, NASA, and NIH generally concurred, and OMB and NSF did not comment on the recommendations.