The Association of American Universities (AAU), Association of Public and Land-grant Universities (APLU), and Council on Governmental Relations (COGR) submitted joint comments to the U.S. Department of Energy (DOE) regarding the agency’s regulatory requirements as part of efforts to reduce administrative burden and regulatory costs under Executive Order 13771. Representing leading research universities across the United States and Canada, the associations identify multiple areas where current DOE processes impose unnecessary complexity, inefficiency, or inconsistency compared to other federal agencies, particularly with respect to DOE-sponsored research. They highlight issues including the lack of standardization in budget justifications and solicitations, unclear and inefficient closeout procedures, inflexible indemnification clauses, inappropriate restrictions on fundamental research, and additional requirements in human subjects research that surpass the federal “Common Rule.” The document details how these burdens add significant administrative overhead and can hinder universities' ability to efficiently conduct research, partner with DOE laboratories, and transfer technology.
The associations offer a series of recommendations aimed at streamlining DOE processes and aligning them with widely accepted federal models, such as those used by the National Science Foundation and the Federal Demonstration Partnership. Key suggestions include adopting standard templates for budgets and solicitations, clarifying and standardizing reporting and invoicing requirements, modifying indemnification language to align with state laws, eliminating unnecessary restrictions on publication and foreign involvement in fundamental research, and removing excess requirements in human subjects protocols. Additionally, they advocate for broader adoption of standard research subaward agreements, reasonable intellectual property terms, and a reconsideration of long-standing practices regarding funding advances and government rights. The letter concludes by expressing appreciation for the opportunity to provide input and offers further discussion on the proposed reforms to facilitate more effective university engagement with DOE-funded research.
This letter provides joint association comments on Department of Energy regulations, paperwork requirements and other regulatory obligations as part of the agency’s implementation of Executive Order 13771, “Reducing Regulation and Controlling Regulatory Costs.”
