The document, presented by Michael Ludwig at the February 2013 COGR meeting, provides an analytical overview of proposed changes and clarifications to federal administrative requirements affecting grant management. Ludwig organizes his assessment into three categories: positive ("Good"), negative ("Bad"), and uncertain ("Unknown") impacts of the new provisions. Highlighted improvements include enhanced guidance on subrecipient monitoring, clearer definitions differentiating procurement actions and subawards, and new standards discouraging voluntary committed cost sharing as a review criterion. The removal of metric system requirements and enforced limitations on additional prior approval mandates by agencies are also positioned as beneficial developments.
Conversely, Ludwig voices substantial concerns regarding increased prescriptiveness and administrative burden, such as expanded requirements for subrecipient oversight, rigorous financial risk evaluations, and more complex reporting mandates—particularly those linking financial data directly to performance outcomes. Additional objections pertain to heightened audit obligations for subrecipients, new rules regarding cost sharing and equipment or supply disposition, and reporting expectations that may undermine standardization efforts. Several areas remain ambiguous, including the depth of risk assessment by federal agencies, notification specifics surrounding award actions, and the treatment of commercial organizations and research leave policies. Collectively, the presentation underscores both the opportunities for improved clarity and accountability in federal research administration, as well as the potential for increased complexity and operational challenges for recipient organizations, especially universities.
