The document, authored by David Kennedy and submitted to the National Research Council Committee on Research Universities in January 2011 by the Council on Governmental Relations (COGR), Association of American Universities (AAU), and Association of Public and Land-grant Universities (APLU), presents a comprehensive critique of the escalating regulatory and financial burdens faced by U.S. research universities in conducting federally funded research. It highlights the importance of compliance and accountability but warns that the current regulatory system is inefficient, overly complex, and misaligned with actual risks, resulting in substantial, often uncompensated costs for universities. The report underscores that a proliferation of agency-specific and duplicative regulations, inflexible administrative cost caps, and increased reporting requirements are undermining university productivity and diverting significant faculty and administrative resources away from core research and educational missions.
To address these challenges, the associations offer ten detailed recommendations to rationalize and streamline federal research regulations. These include harmonizing regulations across agencies, eliminating redundancies and requirements that do not add value, granting research universities exemptions similar to those for small entities, adopting performance-based rather than prescriptive compliance standards, extending existing legislation such as the Unfunded Mandates Reform Act to cover university research, simplifying sub-recipient monitoring, limiting duplicative audits, prohibiting unnecessary cost-sharing requirements, establishing expedited processes for amending laws that create unintended burdens, and appointing a federal ombudsman to coordinate regulatory reforms. The document also provides substantial evidence of the mounting compliance costs and their disproportionate growth relative to research expenditures, stressing that unchecked regulatory accretion is hampering innovation and the effective use of federal funds. The associations express readiness to collaborate further with federal stakeholders to implement these reforms in pursuit of a more efficient and productive federal-university research partnership.
