The document, authored by Erica Froyd and presented at the October 2013 Council on Governmental Relations (COGR) Meeting, outlines the Association of Independent Research Institutes’ (AIRI) perspective on proposed Office of Management and Budget (OMB) grant reform, commonly known as the "omnicircular." AIRI, representing over 80 private, non-profit independent research institutes (IRIs) focused on biomedical and behavioral research, highlights the unique contributions of IRIs, such as their emphasis on research-only missions, smaller size, innovation, and interdisciplinary collaboration. IRIs play a significant role in federally funded research, receiving around 10% of National Institutes of Health (NIH) research project grants, with an above-average grant success rate and considerable funding from agencies like NSF, DOD, DOE, and others.
The presentation details AIRI’s historical engagement with federal cost policy, ongoing efforts to address misunderstandings about IRIs by federal agencies, and collaborative work with COGR on shared policy concerns. Key issues identified in relation to the OMB’s omnicircular include financial and performance reporting, depreciation on assets acquired with non-federal funds, subrecipient monitoring, participant support costs, procurement standards, and reimbursement of trustee expenses. Other concerns include audit standards, effort reporting, cost-sharing implications, predetermined rates, and equipment grant depreciation policies. AIRI emphasizes its commitment to analyzing the omnicircular’s impact, promoting fair and transparent implementation, seeking formal appeal mechanisms, and educating its members on regulatory changes to ensure their interests are represented and protected.
