The document outlines a series of significant developments in federal costing and audit policies affecting research institutions, particularly in relation to reimbursement of indirect (Facilities and Administrative, or F&A) costs. Beginning in September 2010, the National Research Council convened to examine these policies, shortly followed by a Government Accountability Office (GAO) study calling for updates and a COGR (Council on Governmental Relations) paper highlighting the need for consistency across federal agencies. Executive Order 13563 in January 2011 initiated regulatory review, and several task forces were established to address key federal cost principles (A-133, A-87, and A-21). Throughout 2011, ongoing communication and meetings among COGR, agency task forces, and other key stakeholders, such as AAU and APLU, focused on systemic challenges, recommendations for rate setting, simplification of cost principles, and reduction of administrative burden.

Major topics discussed include the limitations on F&A recovery due to arbitrary agency policies, the COGR’s proposal to eliminate effort reporting requirements, best practices for F&A negotiations, and the potential for directly charging project management costs. Additional concerns involve subrecipient monitoring, utility cost adjustments, harmonization of federal regulations, and inconsistent agency restrictions affecting F&A cost recovery. The timeline culminates in early 2012 with the submission of task force recommendations to the Office of Management and Budget (OMB) and updates regarding forthcoming policy steps. The document reflects ongoing efforts to improve federal research funding policies, advocate for greater uniformity, and reduce administrative overhead for educational institutions engaged in federally sponsored research.