This document, prepared by the Council on Governmental Relations (COGR), provides a comprehensive analysis of salary compensation, effort commitments, and certification policies and practices at research institutions in the context of federal regulations. Prompted by significant audit findings and settlements involving millions of dollars, the report addresses concerns about compliance and oversight of federally funded research projects. Emphasizing the longstanding and productive partnership between research institutions and the federal government, the paper underscores that the effective management of compensation and effort reporting is central to maintaining public trust and supporting high-quality science. The document advocates for restoring a critical balance between necessary regulatory oversight and the flexibility required for innovative, productive research environments, cautioning that excessive rigidity in oversight could hinder scientific progress.
COGR’s analysis outlines the challenges and ambiguities that institutions face in implementing policies related to faculty workload, institutional base salary, supplemental compensation, and effort reporting—particularly in interpreting and applying federal guidelines such as OMB Circular A-21. The paper does not set prescriptive standards but instead offers suggested best practices and highlights ongoing issues—like defining allowable workloads, managing cost transfers, and reconciling audit requirements with academic realities. COGR recommends that institutions develop reasonable, internally consistent policies in areas where federal guidance is lacking, and encourages dialogue within the research community and with federal agencies to reduce uncertainty and improve compliance without compromising the flexibility essential for research excellence. The document concludes with a call for collaborative problem-solving to maintain the integrity of research funding and the success of the university-federal research partnership.
