University research is a big business, totaling about $75 billion a year. About $42 billion of this amount comes from federal grants. But do federally imposed administrative requirements divert researchers to focus on non-value-added activities and stymie the effectiveness of their research?
Since 1991, the federal government has imposed 110 new requirements on university research grant recipients. As Professors Barry Bozeman and Jan Youtie noted in a recent article, “Most of these rules are vexing, not life-altering, but . . . taken together, they represent ‘death by a thousand 10-minute tasks.’”
Federal grants that impose administrative burdens on university researchers is not a new topic and has been the subject of dozens of reports over the years. In 2014, the Office of Management and Budget (OMB) took a major step to streamline grant requirements by combining eight circulars into one, commonly called the OMB Uniform Guidance. OMB understood that research grant funds were increasingly being used to meet administrative compliance requirements and hoped that its reforms would “increase the impact and accessibility of programs by minimizing time spent complying with unnecessarily burdensome administrative requirements.”
However, the intended burden reduction did not occur. In fact, a survey of university researchers in a 2018 survey revealed that research time spent on administrative tasks increased to 44 percent.
Part of the reason that burden has not declined, even with new flexibilities in the Uniform Guidance, is the complex interaction among the key players – OMB, the agencies, the auditors, the universities, and the researchers themselves. Each have different priorities and historically they have been unable to come to a common agreement on reducing unnecessary red tape.
Why Existing Flexibilities Are Not Used
OMB is pursuing several cross-agency priority goals intended to reduce administrative burdens to grant recipients and eliminate low-value work as a part of the President’s Management Agenda. In fact, recently OMB released a proposed set of streamlining revisions to the Uniform Guidance for public comment. But given the largely failed history of burden reduction in federal research grants, what seems to be the root causes?
A new IBM Center report by Lisa Mosley, Jeremy Forsberg, and David Ngo points to several reasons, which tie back to the complex relationships among the different stakeholders:
First, the audit community does not interpret policy guidance consistent with that of the federal agencies making grants. This includes federal inspectors general, state audit offices, and private auditors used by universities, and sometimes even the universities themselves. For example, the NSF inspector general questioned $14.3 million in costs at 16 different universities that followed the guidance issued to them by the National Science Foundation (NSF). Ultimately, the NSF inspector general acquiesced, but by then many universities had already put in place policies that reflected the more restrictive interpretation by the NSF inspector general.
Inconsistent audit methods
Second, the audit community uses inconsistent audit methods. As a result, a university that is deemed in compliance by auditors from one federal agency may be deemed out of compliance by an auditor from another agency for the same administrative requirement. For example, a pilot payroll certification project operated by the Federal Demonstration Partnership (a consortium of research universities and federal grant making agencies) between 2011 and 2014 was audited by the inspectors general from both NSF and the Department of Health and Human Services (HHS). The authors write: “The NSF Office of Inspector General determined this alternative methodology provided sufficient accountability over federal funds. However, the HHS Office of Inspector General came to a different conclusion.” As a result, the ripple effect of the HHS audit report “has deterred other universities who may have considered taking advantage of the new flexibilities provided in the 2014 Uniform Guidance.”
Third, both federal agencies and research universities are sensitive to reputational risk. As a consequence, they are reluctant to reduce existing administrative burdens that might result in adverse audit reports. In fact, some universities add their own administrative requirements on top of those imposed by the federal government in an effort to ensure the least risk exposure possible. In addition, there is a history where those universities that do attempt to pilot streamlined approaches are challenged by the audit community for doing so.
The Big Fix?
While Congress recently passed grant streamlining legislation and OMB is proposing revisions to the Uniform Guidance, Mosley, Forsberg, and Ngo conclude that stakeholders from across the research grant ecosystem need to come together and develop a joint, comprehensive strategy to address unnecessary administrative burdens. They note that in 2016 Congress passed legislation to create a Research Policy Board to be the forum for developing such an approach but this Board has never been convened. The authors recommend that OMB create this Board.