I am Brian Harvey, Assistant Vice President for Research and Director of
the Division of Sponsored Programs at the University of Iowa. Presently
we have federally sponsored programs worth over \$280 million at work in
11 colleges. I have been a research administrator for 35 years and
welcome this opportunity to comment at the OSTP Regional Forum on
Research Business Models hosted by the University of Minnesota on the
theme of "Common Practices among Agencies." My comments are pertinent to
both the morning and afternoon panels.

First let me say how important federal funding is to the discovery of
new knowledge for this nation\'s future. You are to be commended for
your attention to the critical partnership that has brought all this
about.

Efforts made over many years to develop and implement uniform grant
application policies and procedures and uniform grant administration
regulations among all federal grant funding agencies have consistently
been thwarted by agencies unwilling to work with one another to
compromise on common rules. Now, more than ever, with the advent of
electronic means of applying for grants, receiving notification of grant
awards, drawing down funds, and providing technical and financial
reports, it is essential that uniform processes be developed and put to
use. With federal granting agencies going in different directions with
their electronic systems it is becoming even more difficult for grantee
institutions to apply for and accept federal funding. The costs of
maintaining highly trained staff and technology are driving up the costs
of doing business with the federal government. Smaller institutions
lacking the resources to adapt to the increasing complexity of doing
business risk exclusion from the process. These electronic processes go
by many different names: FastLane, E-SNAP, NIH Commons, IIPS, CDMRP
E-Submission, SGMS, e-grants, etc., requiring a myriad of passwords and
user IDs to keep track of. The electronic procedures that some agencies
have developed by-pass internal institutional review requirements or are
becoming so complex that ingenious applicants are able to circumvent
internal procedures. At the University of Iowa, we had a faculty member
who was inadvertently registered by NSF as an institutional official and
was having NSF FastLane grant applications forwarded to him for
submission, without the knowledge of the University's Sponsored Programs
Office.

Attention needs to be focused on Public Law 106-107, the Federal
Financial Assistance Management Improvement Act of 1999. Implementation
of this law needs to get on a faster track before federal agencies
invest too much time and money developing their own systems and thereby
increase their stakes in them. The initial OMB notice implementing this
law dealt with streamlining the grant announcement mechanisms by
developing standard formats and common datasets to be used under the
E-Grants initiative. Revisions are also proposed to clarify ambiguous
language in the Federal Cost Principles contained in A-21, A-87, and
A-122, thereby preventing inconsistent interpretations of similar cost
items across the three circulars. These are excellent steps in the right
direction, but similar efforts need to be made in the grant
administration regulations that regulate the application, award and
postaward procedures. Similar streamlining efforts need to move
post-haste in other areas such as:

##### Applications:

-   establish standard data elements for required general and budgetary
    information;

-   eliminate burdensome and ambiguous cost-sharing requirements;

-   eliminate unnecessary certifications and assurances;

-   establish common language for assurances;

-   improve the process for sharing information about certifications and
    assurances among federal agencies; and

-   state clearly any cost-sharing or matching requirements and avoid
    vague references to expectations of institutional contributions.

##### Awards:

-   establish standard data elements for information on award documents;

-   eliminate agency-specific terms and conditions found to be
    unnecessary;

-   state explicitly whether or not expanded authorities apply or not;

-   state explicitly both mandatory and voluntary committed cost-sharing
    expectations;

-   develop common language for award terms and conditions, including
    administrative and public policy requirements; and

-   achieve greater uniformity in placement of terms and conditions
    within award documents.

##### Reporting:

-   develop standards, including standard data elements, for property,
    invention, and environmental reporting;

-   eliminate unnecessary differences in the required number of report
    copies and frequency of reporting; and

-   provide technical assistance and training for award recipients and
    identify federal agency best practices.

On the topic of inconsistency of policies and practices among
universities, grantee institutions can be their own worst enemies.
Collaborations or consortia of grantee institutions have become
commonplace and will increase since NIH places interdisciplinary
research as a high priority, but the subcontracting process is more
burdensome than it ought to be. Universities and state agencies put into
their subagreements with collaborating universities terms and conditions
that they themselves would strongly object to if the agreements were
coming directly from federal agencies. Examples include unacceptable
indemnification and insurance clauses, publication restrictions, and
prior approval requirements that exceed minimum requirements of A-110
and similar circulars. Subagreements between universities generally
require months to negotiate, severely hampering the research process.
The entire subcontracting process, including the requirements for
monitoring and audit, needs to be streamlined. The Federal Demonstration
Project is making great strides at simplifying the process, but the
federal government should initiate a study of the problems and develop
recommendations on ways to simplify the process even further, at least
for subagreements under grants.

Similar problems occur to an even greater extent with Material Transfer
Agreements, or MTAs. Providers of research materials impose excessive
indemnification requirements and intellectual property stipulations that
virtually make it impossible for public institutions to have easy access
to these important research materials. The simplified form that NIH
developed and promoted several years ago needs to be streamlined further
and made mandatory for MTAs associated with NIH grants. NIH consistently
violates its own best practices guidelines in this area by issuing MTAs
with objectionable language and being unwilling to accept modifications.

An example of extreme over-regulation has to do with cost sharing. In an
effort to force grantee institutions to document cost sharing in order
to drive down facilities and administrative costs, researchers are now
required to document and differentiate their research effort by
recording how they spend their time in terms of the time that they were
paid for by the grant, the time that they said they would spend on the
grant and not get paid for, and the time that they decided they spend on
the research project in addition to the other ways they reported. This
is extending accountability to unreasonable extremes and, like other
inconsistencies and inadequacies evident in the current federal granting
policies, procedures, and regulations discussed in this report, is a
serious distraction from the main purpose of the funds: performing
high-quality research.

Thank you again for the opportunity to speak from a research
university\'s perspective.