The OMB Grants Reform Letter (April 2012), authored by Anthony P. DeCrappeo on behalf of the Council on Governmental Relations (COGR), conveys collective feedback from leading U.S. research universities regarding proposed federal grant policy reforms. COGR emphasizes the need for reforms that reduce administrative burden and realize cost savings, but not at the expense of undermining compliance, accountability, or the operational effectiveness of research institutions. The letter highlights the pivotal role universities play in federally funded research and asserts that reforms should be rooted in fairness, equity, and transparency. Specific concerns addressed include arbitrary federal cost reimbursement policies, the need for a transparent and consistent indirect cost (F&A) rate negotiation process, consistent implementation of voluntary cost sharing policies across agencies, exemptions from mandatory cost sharing, and the elimination of duplicative or burdensome audit and administrative requirements.
COGR systematically reviews and responds to OMB’s proposed reform ideas, supporting many measures—such as the simplification of effort reporting, expansion of utility cost adjustments, and standardized funding announcements—provided they yield genuine administrative relief. However, COGR opposes the consolidation of cost principles into a single document and the use of flat F&A rates, arguing that such moves could impose inequitable financial burdens on research institutions. The letter also underscores the importance of protecting research universities from unfunded mandates and cost-shifting, especially concerning unreimbursed facility and administrative costs, while advocating for mechanisms that increase regulatory efficiency and accountability, such as the establishment of a federal ombudsman and streamlined audit processes. The overarching tone is collaborative but cautious, urging OMB to ensure that reforms do not inadvertently compromise the nation’s research infrastructure or the long-standing federal-academic partnership.
OMB Advance Notice of Proposed Guidance, April 2012.
for the letter.
