The Council on Governmental Relations' July 28, 2011 document presents a thorough set of recommendations to the Office of Management and Budget (OMB) aimed at alleviating administrative and regulatory burdens faced by research institutions—particularly universities, non-profit organizations, and academic medical centers—in the management of federally funded research. The primary themes emphasize the need to reduce unnecessary costs and inefficiencies while sustaining high standards of compliance and accountability.
Key recommendations focus on clarifying and simplifying existing regulations to support faculty productivity and administrative efficiency, as well as ensuring the fair and consistent enforcement of current rules. The Council highlights the adverse effects of fragmented and overlapping federal requirements which often result in unintentionally duplicative reviews, conflicting definitions, inconsistent training mandates, and inflated compliance costs—all of which impede research productivity. Specific proposals include replacing burdensome effort reporting requirements with more flexible, institution-based payroll systems, allowing for the direct charging of essential project management and research communications costs, and streamlining subrecipient monitoring for audited entities.
A cornerstone of the recommendations is the call for greater harmonization and coordination of regulatory and audit practices across all federal agencies, including consistent application of indirect (F&A) cost recovery rates and the elimination of arbitrary funding caps and cost-sharing requirements unless explicitly required by statute. The Council also advocates modernizing documentation retention policies to fit current electronic record-keeping, and calls for the elimination of duplicative or obsolete regulatory provisions.
Recognizing the rising costs of compliance, the Council urges the stabilization and adequate funding of critical infrastructure such as Grants.gov, the establishment of a Federal Ombudsman within OMB, and the incorporation of cost of compliance analyses into regulatory and legislative processes. Additionally, it recommends extending targeted exemptions to research institutions, similar to those offered to small businesses, to ensure regulatory demands are proportionate to organizational resources and capacities.
Collectively, the measures are intended to streamline federal oversight, enhance agency accountability, and enable research organizations to effectively recover compliance costs, thereby freeing up more resources for the core mission of research. The document underscores the importance of stakeholder engagement and a responsive governance structure that can address the specific needs of the research community, ultimately supporting a more efficient and robust federal research enterprise.
