The "A-21 Task Force Document on Effort Reporting Requirement," authored by David Kennedy and representing the Council on Governmental Relations (COGR), presents a comprehensive argument for discontinuing the traditional federal effort reporting requirement in research institutions. The document, addressed to the A-21 Task Force and related federal bodies, critiques the current system of effort reporting as administratively burdensome, costly, and inefficient, arguing it does not effectively measure institutional compliance or research value. Instead, COGR advocates for the adoption and formal endorsement of institution-specific, compliance-based payroll distribution systems, supported by robust internal controls, as a more effective and less onerous alternative for accountability in federal research funding. The organization urges the Office of Management and Budget (OMB) to clarify policy through a memorandum and proposes a phased implementation across institutions to facilitate a smooth transition.
COGR’s proposed model framework centers on modern payroll distribution systems integrated with preventive and detective controls, ongoing monitoring, and consistent review processes by responsible personnel. The document outlines common characteristics that these systems should uphold: electronic reporting, comprehensive coverage, uniformity, routine verification, and audit integrity, among others. Furthermore, COGR submits detailed recommended changes to OMB Circular A-21 Section J.10, emphasizing principle-based standards over prescriptive solutions and calling for flexibility to account for institutional differences. The overarching goal is to strengthen accountability for federal research expenditures while significantly reducing unnecessary administrative barriers and allowing researchers to focus on advancing scientific knowledge.
