**From:** Brian Prindle \[prindle@ufl.edu\]

**Sent:** Monday, October 06, 2003 3:52 PM

**To:** NSTC_RBM

**Cc:** Tom Walsh

**Subject:** NSTC Response.doc

 

October 6, 2003

 

 

Michael J. Holland

Office of Science and Technology Policy

1650 Pennsylvania Avenue, NW

Washington D.C.20502

 

Subject: NSTC Research Business Models Comment

 

Dear Dr. Holland:

 

The University of Florida is pleased to respond to the Office of Science
and Technology Policy's request for information as published in volume
68, number 151 of the federal register dated August 6, 2003.

 

A.  **A.     Accountability. What constitutes accountability for the
    Federally-supported research enterprise? How can performers best
    demonstrate results or return on Federal research investments?
    Please suggest mechanisms whereby research managers can more
    transparently demonstrate responsible use of public resources.**

** **

**Comment:** The principal measure of accountability must remain focused
on the research activities and outcomes. We advocate for open scientific
communication. The federal government must continue to support this open
and free ability for Investigators to exchange information and publish
their findings.

 

**Comment:** Annual and Final technical reports delivered to program
officers is an effective means by which grant performance can be
measured.

 

**Comment:** Fiscal accountability is also very important and current
practices of reporting expenditure information through the quarterly and
final Federal Cash Transaction Report, SF 272. works well.

 

A.  **B.     Inconsistency of policies and practices among Federal
    agencies. Can you identify specific Federal policies and practices
    that if simplified would improve the efficiency and cost
    effectiveness of the research enterprise? Can the impact of
    inconsistent policies and practices among Federal agencies on the
    research environment be quantified?** **Among the variations in
    policies and practices, which practices appear to be the best?
    Why?**

 

**Comment:** The purpose of OMB Circular A-110 is to set forth standards
for obtaining consistency and uniformity among Federal agencies in the
administration of grants and agreements with institutions of higher
education, hospitals, and other non-profit organizations. OMB in
November 1993 issued a revised A-110 circular with instructions that
each grant making federal agency codify this revision. The codification
process resulted in at least 12 different versions of OMB circular A-110
(refer to:
[[http://www.whitehouse.gov/omb/grants/chart.html]{.underline}](http://www.whitehouse.gov/omb/grants/chart.html)).
Prior to 1993, universities worked with a single version A-110 now we
must work with a dozen slightly different versions. The main target of
agency variations is found in, section 25, entitled Revision of Budget
Plan and Program Plans, where prior approvals such as no cost
extensions, pre-award costs, carry forward, and A-21 are waived or not
waived. For consistent management of grants, OMB should re-state section
25 and require all agencies to re-codify. One example of a clearly
written section 25 was accomplished by the EPA, which could be used as
the standard.

** **

**Comment:** Lack of clarity about cost sharing and expectations is
still a problem as many agency issue request for proposals or program
guidelines that make ambiguous statements such as "cost sharing is
highly recommended" or "cost sharing is strongly encouraged" with no
further explanation as to how such cost sharing will be used in the
award selection process. Funding announcements must make it clear that
cost sharing is either an eligibility criterion only and/or is being
used as a review criterion. Universities are not adverse to committing
to cost sharing in grant applications when appropriate, but when we have
accounting rules that penalize universities from cost sharing we are put
in a position to strongly discourage cost sharing any project. These
accounting rules need to be reviewed so that Universities are not
penalized for cost sharing.

 

**Comment:** We see a growing number of special indirect cost rates that
are being imposed upon grantees through special programs announcements.
It would be preferred that all programs should use the Federal
negotiated rates of an institution and not have selective programs with
special rates.

 

**Comment:** The University of Florida uses multiple payment systems
deployed by various federal agencies. A description of each is provided
below. Having multiple payment systems has increased costs.  For example
we need a dedicated phone line and modem for the ONR EDI system. 
Initial costs were software, installation of modem and line, training. 
Recurring costs are monthly telephone service and maintenance on
dedicated line, monthly costs of Value Added Network (VAN) service
(\~\$500 per year) and annual software maintenance and license fee
(\~\$500 per year).

 

+-----------------+------------------------------+------+--------------+
| Federal Agency  | Required Payment System      | Web  | Burden       |
|                 |                              |      |              |
|                 |                              | S    |              |
|                 |                              | ervi |              |
|                 |                              | ces? |              |
+-----------------+------------------------------+------+--------------+
| Agency for      | Payment Management System    | Yes  | The burden   |
| International   |                              |      | on our       |
|                 | (PMS) Web Site               |      |              |
| Development     |                              |      | financial    |
|                 |                              |      | system       |
|                 |                              |      |              |
|                 |                              |      | includes the |
|                 |                              |      | time         |
|                 |                              |      |              |
|                 |                              |      | consumed in  |
|                 |                              |      |              |
|                 |                              |      | maintaining  |
|                 |                              |      | multiple     |
|                 |                              |      |              |
|                 |                              |      | systems.     |
|                 |                              |      | Training     |
|                 |                              |      |              |
|                 |                              |      | and cross    |
|                 |                              |      | training for |
|                 |                              |      |              |
|                 |                              |      | all the      |
|                 |                              |      | various      |
|                 |                              |      | systems      |
|                 |                              |      |              |
|                 |                              |      | requires     |
|                 |                              |      | extra time.  |
|                 |                              |      |              |
|                 |                              |      |              |
|                 |                              |      |              |
|                 |                              |      | Add\'l time  |
|                 |                              |      | has been     |
|                 |                              |      |              |
|                 |                              |      | spent when   |
|                 |                              |      | agencies     |
|                 |                              |      |              |
|                 |                              |      | change from  |
|                 |                              |      | one          |
|                 |                              |      |              |
|                 |                              |      | system to    |
|                 |                              |      | another.     |
+-----------------+------------------------------+------+--------------+
| Department of   | Financial Assistance         | Yes  |              |
| Commerce        | Disbursement                 |      |              |
|                 |                              |      |              |
|                 | System (FADS) Web Site       |      |              |
+-----------------+------------------------------+------+--------------+
| Department of   | Payment Management System    | Yes  |              |
| Agriculture     | (PMS) Web Site               |      |              |
+-----------------+------------------------------+------+--------------+
| Department of   | Grant Administration and     | Yes  |              |
| Education       | Payment                      |      |              |
|                 |                              |      |              |
|                 | System (GAPS) via web        |      |              |
+-----------------+------------------------------+------+--------------+
| Department of   | Automated Standard           | No   |              |
| Energy          | Application for              |      |              |
|                 |                              |      |              |
|                 | Payment (ASAP)               |      |              |
+-----------------+------------------------------+------+--------------+
| Department of   | Payment Management System    | Yes  |              |
| Health          |                              |      |              |
|                 | (PMS) Web Site               |      |              |
| and Human       |                              |      |              |
| Services        |                              |      |              |
+-----------------+------------------------------+------+--------------+
| Environmental   | Automated Standard           | No   |              |
| Protection      | Application                  |      |              |
|                 |                              |      |              |
| Agency          | for Payment (ASAP)           |      |              |
+-----------------+------------------------------+------+--------------+
| Department of   | Payment Management System    | Yes  |              |
| Interior        |                              |      |              |
|                 | PMS) Web Site                |      |              |
+-----------------+------------------------------+------+--------------+
| Department of   | Line of Credit Control       | No   |              |
| Housing         | System                       |      |              |
|                 |                              |      |              |
| and Urban       | (LOCCS) voice response       |      |              |
| Development     |                              |      |              |
+-----------------+------------------------------+------+--------------+
| National        | Faxed SF 270                 | No   |              |
| Endowment for   |                              |      |              |
|                 |                              |      |              |
| the Humanities  |                              |      |              |
+-----------------+------------------------------+------+--------------+
| Department of   | Mailed SF 270                | No   |              |
| Justice         |                              |      |              |
+-----------------+------------------------------+------+--------------+
| Department of   | Mailed SF 270                | No   |              |
| Labor           |                              |      |              |
+-----------------+------------------------------+------+--------------+
| National        | Payment Management System    | Yes  |              |
| Aeronautics &   | (PMS)                        |      |              |
|                 |                              |      |              |
| Space           | Web Site Some branches not   |      |              |
| Administration  | on                           |      |              |
|                 |                              |      |              |
|                 | PMS - require qtrly 272      |      |              |
|                 | mailed                       |      |              |
+-----------------+------------------------------+------+--------------+
| Department of   | ONR - Information Exchange   | Yes  | The ONR      |
| Defense         | System (IES)                 |      | system       |
|                 |                              |      |              |
|                 | to draw and EDI-Eagle to     |      | requires us  |
|                 | send                         | No   | to buy       |
|                 |                              |      |              |
|                 | AFOSR - Mailed SF 270        | No   | expensive    |
|                 |                              |      | software     |
|                 | ARO - Mailed SF 270 (unless  |      |              |
|                 |                              |      | with monthly |
|                 | preplanned schedule of pmts) |      | charges.     |
+-----------------+------------------------------+------+--------------+
| National        | Fastlane                     | Yes  |              |
| Science         |                              |      |              |
|                 |                              |      |              |
| Foundation      |                              |      |              |
+-----------------+------------------------------+------+--------------+

 

**Comment:** To promote cost efficiencies one payment system should be
deployed for use by all federal agencies.

 

**Comment:** For an example of best practices of grant policies and
procedures that would simplify, improve, and set forth consistency
please review the Federal Demonstration Partnership and the FDP standard
terms and conditions. Approximately 90 schools and 11 federal agencies
are members of the FDP and we have accomplished streamlining and
improving the federal/university research support relationship, which
allows our Investigators to focus on the science of these projects. As
an example FDP maintains a prior approval matrix
([[http://www.nsf.gov/pubs/fdp/fdpmatrix.xls]{.underline}](http://www.nsf.gov/pubs/fdp/fdpmatrix.xls))
that is a very efficient tool used regularly in our grant administration
business.

 

The National Science Foundation presents another best practice
opportunity. The NSF has a complete suite of user friendly grant
application guidelines, terms and conditions, and a full service
electronic grant management system called FASTLANE.

 

B.  **C.     Inconsistency of policies and practices among universities.
    Can you identify specific university policies and practices that if
    simplified would improve the efficiency and cost effectiveness of
    the research enterprise?**

> ** **

**Comment:** FDP identified inconsistent policies and practices between
institutions when subawarding or subcontracting effort under a prime
grant agreements was to occur. FDP over a two year period implemented a
demonstrated that by using a FDP developed standard subaward template
the award process was streamlined and administrative burden reduced
dramatically. Below are some highlights of the FDP subaward project.

 

· 768 subawards using the model subaward agreement form have been issued

· 746 of these were issued without changes

· 11 cases required major changes to be negotiated prior to signature

· On average, institutions saved 21 pages per subaward issued

· 73% of those responding reported time savings

 

> **E. Regulatory requirements. Is there a more efficient approach to
> meeting the intent of the current suite of administrative requirements
> and regulations? Please provide examples.**

 

**Comment:** An example of an efficient tool that is used regularly by
our grant administration staff is

The FDP prior approval matrix (refer to:
[[http://www.nsf.gov/pubs/fdp/fdpmatrix.xls]{.underline}](http://www.nsf.gov/pubs/fdp/fdpmatrix.xls)).

 

**Comment:** In 1996 Universities were required to submit a description
of its cost accounting practices to the cognizant federal agency for
approval. The document submitted is known as the DS-2. To date only a
few schools have received an approval of their DS-2. The rest of us have
been put on hold. A more efficient approach would have been to keep this
as a disclosure document with no approval process. Cost savings and the
burden of having to audit and approve the DS-2's would have been
relieved. Cognizant federal agencies are then free to audit the DS-2 of
any institution when needed.

 

> **I. Information Technology. How has information technology impacted
> the efficiency, performance, or costs of research management? Are
> there data to demonstrate any effect?**

 

**Comment:** In response to PL 106-107, agencies have independently
developed electronic grant application systems that have resulted in
inefficiencies and chaos. Many of these systems by-pass the institutions
sponsored research offices where Institutional Approval is obtained
prior to submission of a grant application. This indicates a lack of
understanding of research administration by agency system developers.
Institutional costs associated with maintaining these different systems
are high. We absorb paying for training of faculty and staff, upgrades
for software and hardware, and on-going maintenance of multiple systems.

**Comment:** Provide a common system, which takes advantage of the best
aspects of systems, such as NSF's FastLane. Allow continuous input for
both the users and the participating agencies to continually improve the
system. Stagger deadlines so as to not overload the systems and, if
overload occurs, provide for some flexibility to avoid penalizing the
users. Do not allow grant application deadlines to be published that are
beyond the close of business (normally 5PM). As an example, one federal
agency recently had a published deadline of 12:00 midnight. One
investigator at the University insisted someone be available for
assistance if they had trouble with the e-application system. We had to
respectfully say they were on their own at such a late hour. The point
being, faculty and staff should not be put into such a situations.

 

**Comment:** It appears that the concepts of the Federal Commons now
know as Grants.gov is still not being fulfilled. There are a multitude
of committees at various levels working on policy and oversight,
business practices and standards and various demonstration projects. It
is not clear how all the information and the results are being developed
so that there is no confusion in the user community about the various
approaches to electronic research administration, there are fewer
independent systems, there are uniform data standards, and costs are not
prohibitive.

** **

> **J. Technology transfer optimization. Are data available to examine
> whether intellectual property and patent agreements have changed
> relationships among universities, industry, and the government?**

 

**Comment:** We would recommend use of the Association of University
Technology Manager (AUTM), which collects and publishes annual
statistical reports that provide this information and much more.

 

Sincerely,

 

 

 

Dr. Thomas E. Walsh

Director of Research and Compliance

University of Florida

[ ]{.underline}