A recent (28 February 2017) CRS report of special interest to many of my colleagues in academia: Federally Funded Academic Research Requirements: Background and Issues in Brief by Laurie A. Harris and Marcy E. Gallo.
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For decades, the federal government and academic research institutions have been partners in supporting American innovation, competitiveness, and economic growth. The federal government is the largest source of academic research and development (R&D) funding in the United States, providing funds through more than two dozen federal agencies, with the National Institutes of Health (NIH) and the National Science Foundation (NSF) providing the largest portions of federal R&D funding to U.S. colleges and universities.
As part of oversight of federal funding for academic research, Congress and federal agencies have established requirements through statutes, regulations, and guidance documents that U.S. universities and other research institutions must comply with when applying for, receiving, and reporting on the results of federal research grants. Such requirements seek to ensure transparency and effectiveness of federal funds, while helping to prevent waste, fraud, and abuse.
Academic research institutions broadly recognize the need for, and benefits from, federal regulations but have raised concerns that federal regulations and administrative requirements have produced unintended consequences, such as reducing research productivity and the return on federal investments. Surveys and assessment reports conducted over the past two decades have evaluated the benefits and challenges related to federal requirements for academic research. Among specific areas of concern frequently brought forth by researchers and academic administrators are the amount of time spent on completing administrative tasks compared to conducting research; the increasing number, and lack of harmonization, of requirements across federal funding agencies; the adequacy of stakeholder engagement in the review and modification of federal regulations; and the need for updated requirements for human subjects and animal research.
Legislation was enacted in the 114th Congress that addressed a number of the concerns, including the 21st Century Cures Act (P.L. 114-255), the American Innovation and Competitiveness Act (AICA, P.L. 114-329), and the National Defense Authorization Act for Fiscal Year 2017 (NDAA, P.L. 114-328). Enacted provisions addressed a subset of issues focused on specific agencies, including conflicts of interest disclosure, financial reporting, and subrecipient monitoring. Enacted provisions also addressed cross-agency efforts by directing the establishment of an advisory committee (Research Policy Board) with federal and non-federal stakeholders, as well as an interagency working group (WG) on federal research regulations.
The 115th Congress may conduct oversight as agencies work to implement the provisions enacted in the 114th Congress. Congress may further consider legislation to extend certain provisions more widely across the federal government. For current and potential future efforts to streamline and harmonize federal regulations, a central consideration will likely be ensuring that mechanisms to evaluate transparency and accountability of federal funds are not diminished.
The amount of time and costs associated with regulations and requirements for federally funded academic research are of ongoing concern to scientists and administrators. Legislation passed by the 114th Congress to address many of the long-standing issues raised in recent reports has had broad support from the scientific community, though challenges and uncertainties remain. Academic institutions can help maximize federal efforts to streamline and harmonize requirements by working to improve their own internal policies and procedures.
As prior assessments have noted, no one regulation or policy is the major cause of stakeholder concern; rather, it is the cumulative impact across a range of requirements. Congressional oversight may be an important part of monitoring the progress of implementing the provisions enacted in the 114th Congress in a holistic way and evaluating their overall effectiveness. Further, Congress may broadly consider the appropriate balance between supporting the nation’s academic research enterprise through efforts to streamline regulations and maintaining mechanisms for oversight, transparency, and accountability. Forthcoming assessments from such efforts as the revised Common Rule, final guidance from payroll certification pilot programs, and OMB review of UG components, may help to inform any future efforts to optimize federal research policies.