The document outlines the discussion and recommendations surrounding the implementation of changes to the federal Circular A‐21 policy, specifically concerning the direct charging of costs associated with project management activities in sponsored research projects. The primary argument, advanced by the Council on Governmental Relations (COGR) and exemplified by Duke University’s response, is that existing methodologies for cost allocation are outdated and do not account for the increasing complexity and administrative burden of contemporary research compliance. COGR recommends that the Office of Management and Budget (OMB) clarify and revise the regulations to explicitly allow, as a direct cost, allocable project management activities that can be specifically identified with an individual project—such as protocol and compliance support, purchasing, staff recruitment, and travel arrangements. These changes are intended to better align cost treatment with actual research practices, enhance faculty productivity by relieving them from administrative duties, and maintain accountability while reducing prescriptive and burdensome cost-accounting requirements.
Duke University, supporting these recommendations, highlights both the evolving nature of professional research support roles and the substantial institutional cost increases associated with research compliance. The university proposes clear policy and procedural guidelines to differentiate project management support from routine clerical and technical functions, and emphasizes the importance of consistency and auditor alignment in implementation. The overall goal is to recognize and directly charge project-specific administrative activities, thus reflecting the true costs of research projects and supporting faculty in focusing more fully on their research responsibilities. The document concludes by noting the need for further policy development and clarity in roles to ensure effective adoption of the proposed A‐21 changes.
