You may recall that back in February 2012 I blogged about OMB’s request for comment on proposed reforms to federal grant policies contained in Office of Management and Budget (OMB) circulars such as A-21, A-133, and A-122. OMB proposed these reforms to streamline Federal policies relating to grants. The essential idea behind this reform is to reduce the “red tape” and unnecessary or overly burdensome requirements so that grantees can better focus their efforts achieving their research objectives.
The prior Advanced Notice of Proposed Guidance (ANPG) received more than 350 public comments, all of which OMB has considered carefully in drafting the proposed rule issued on February 1, 2013 in the Federal Register (note that there are two primary documents: the preamble and the full text of the proposed rule). I am pleased to note that the public’s feedback has influenced the draft guidance greatly and OMB has opened the latest version of the proposed rule for public comment once again.
Providing comments and feedback on the proposed rule is an important opportunity for the grants community because their comments can be used to further refine the reforms before the final guidance is issued. I described the scope of the proposed reform in my previous blog post, and I suggest that you read the Federal Register notice in full, but I want to highlight some key areas on which OMB seeks specific feedback, as these topics are highly relevant to the NIH research administration community:
- Proposed audit language for time and effort reporting requirements. OMB is asking whether the language proposed adequately provides enough flexibility for institutions to meet these standards in the way most appropriate to their particular organizations.
- Revisions to reimbursement for utility costs to institutions of higher education.
- One time extension of indirect (“F&A”) costs for all types of institutions, i.e. the option of extending negotiated rates for up to 4 years subject to approval of the indirect cost cognizant agency.
There are many more issues raised in the proposed rule; again, I encourage you to read the notice in its entirety. Please note the 26% limitation on reimbursement of administrative costs remains for institutions of higher education and would not apply to other types of institutions such as non-profit organizations.
Also, please note that OMB offers a number of resources and supporting documents comparing current requirements and proposed changes to help you navigate the proposed changes. Some of you may also be interested in viewing the upcoming webcast on Feb. 8 at 11 am EST, hosted by OMB and the Council on Financial Assistance Reform.
Both Federal agencies and the public are invited to submit comments at www.regulations.gov; the last day comments will be accepted is May 2, 2013. My office has been providing comments throughout the development of this guidance, and will do so again now. I encourage you to share your thoughts with OMB too.