The document, authored by David Kennedy and representing the Association of American Universities (AAU), the Association of Public and Land-grant Universities (APLU), and the Council on Governmental Relations (COGR), presents a series of recommendations to the National Research Council (NRC) aimed at reforming federal research policy and regulatory structures as they pertain to U.S. research universities. These organizations argue that while regulatory oversight and compliance are critical to the integrity and effectiveness of federally funded research, the existing regulatory environment has become excessively burdensome, with overlapping, inconsistent, and often unfunded mandates that significantly increase administrative costs and divert valuable faculty time from core research and teaching activities. The recommended reforms focus on harmonizing and streamlining regulations across federal agencies, eliminating redundant or low-value requirements (such as effort reporting), extending regulatory flexibility and exemptions similar to those provided to small entities, and incorporating performance-based approaches rather than prescriptive process mandates.
A central theme of the document is the escalating financial and productivity costs of compliance, which are not adequately reimbursed under the current 26 percent cap on administrative cost recovery. Specific recommendations include allowing direct charging of certain administrative costs to federal grants, adjusting the administrative cap, simplifying sub-recipient monitoring, prohibiting voluntary committed cost sharing, and introducing mechanisms to regularly review and rapidly amend statutory and regulatory burdens that do not serve substantive policy objectives. The establishment of a dedicated Federal Ombudsman within the Office of Management and Budget (OMB) is also proposed to facilitate interagency coordination and respond to university concerns. The document is supported by case studies and quantitative data illustrating the disproportionate growth of compliance-related expenditures relative to research funding over time, and offers detailed suggestions for targeted regulatory relief across various compliance domains. These reforms, the associations contend, would improve research productivity, foster a more rational regulatory climate, and ultimately enhance the cost-effectiveness of the federal research enterprise without necessitating significant new federal spending.
