FEDERAL 

RESEARCH 

GRANTS

Opportunities Remain 

for Agencies to 

Streamline 

Administrative 

Requirements

Statement of John Neumann, Director, Natural Resources 

and Environment

Testimony before the Subcommittee on 

Research and Technology, Committee 

on Science, Space, and Technology, 

House of Representatives

For Release on Delivery 

Expected at 10:00 a.m. ET

Thursday, September 29, 2016

GAO-16-890T

United States Government Accountability Office
Page 1 GAO-16-890T 

Chairwoman Comstock, Ranking Member Lipinski, and Members of the 

Subcommittee:

I am pleased to be here today to discuss administrative requirements on 

federal research grants to universities, as well as federal agency efforts 

and opportunities to streamline such requirements. According to National 

Science Foundation (NSF) data, the federal government funds the 

majority of research performed by colleges and universities, obligating 

over $27 billion for such research in fiscal year 2015.1 To allow for 

oversight, Congress and federal agencies have established a variety of 

administrative requirements for the use of these funds.2 Some 

requirements were established or strengthened in response to cases of 

researchers improperly spending funds or because of concerns about 

research integrity. Others were established to meet broader policy 

objectives, such as increasing access to research data and results.

During the last two decades, organizations that have studied these 

requirements have raised concerns about the administrative workload 

and costs for researchers and universities to comply with the 

requirements and their effects on the efficient conduct of research. In 

addition, several executive orders and a presidential memorandum have 

called for streamlining regulations and guidance to reduce grantees’

administrative workload and costs. For instance, Executive Order 13563 

of January 18, 2011 called for greater coordination across agencies to 

simplify and harmonize rules, and for agencies to consider regulatory 

approaches that reduce burdens and maintain flexibility. In December 

2013, the Office of Management and Budget (OMB) consolidated its 

grants management circulars into a single document—the Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements 

for Federal Awards (Uniform Guidance)—to streamline its guidance and 

 

1National Science Foundation, National Center for Science and Engineering Statistics, 

Higher Education Research and Development Survey, Fiscal Year 2014 (November 2015) 

and Survey of Federal Funds for Research and Development, Fiscal Years 2014–16 (April 

2016). NSF data include funds for basic research, applied research, and development. For 

purposes of this testimony, we generally refer to these funds as research funding. NSF’s 

data for fiscal year 2015 are preliminary.

2Some provisions governing these funds appear in statutes or regulations, and others 

appear in agency guidance documents. For purposes of this testimony, we refer to all of 

these provisions as “requirements.”

Letter
Page 2 GAO-16-890T 

reduce the administrative burden on nonfederal entities, as well as to 

strengthen oversight of federal funds to reduce risk of waste, fraud, and 

abuse.3 Nevertheless, universities and stakeholder organizations continue 

to cite increasing administrative workload and costs for complying with 

requirements.

My statement today summarizes our June 2016 report on administrative 

requirements on federal research grants,4 which examined (1) selected 

research grant requirements, (2) the factors that contribute to universities’

administrative workload and costs for complying with these requirements, 

and (3) efforts OMB and research funding agencies have made to reduce 

the administrative workload and costs for complying with these 

requirements, and the results of these efforts. For our report, we selected 

and examined administrative requirements in nine categories that multiple 

universities and university stakeholder organizations had cited as 

contributing to universities’ administrative workload and costs, had been 

the subject of recent streamlining efforts or other changes, or had been 

part of the findings of recent reports by agency inspectors general.5 We 

reviewed guidance, regulations, and other documentation of the 

requirements and interviewed officials at OMB and four research funding 

agencies—the Department of Energy (DOE), National Aeronautics and 

Space Administration (NASA), National Institutes of Health (NIH), and 

NSF—which together provided about 83 percent of federal funding for 

research at universities and colleges in fiscal year 2015. We reviewed 

documentation from and interviewed administrative staff and researchers 

at six public and private universities that vary in the amount of research 

funding they receive and in other characteristics. We also interviewed 

representatives of several university stakeholder organizations. The 

results of our reviews of selected requirements, agencies, universities, 

and stakeholder organizations cannot be generalized to those not 

included in our review. More detailed information on our scope and 

methodology can be found in our June 2016 report. We conducted the 

 

3The Uniform Guidance is implemented through individual federal agency regulations that 

were to take effect no later than December 26, 2014.

4GAO, Federal Research Grants: Opportunities Remain for Agencies to Streamline 

Administrative Requirements, GAO-16-573 (Washington, D.C.: June 22, 2016). 

5For example, these include requirements related to research project budgets, research 

personnel, and oversight of subrecipients.
Page 3 GAO-16-890T 

work on which this statement is based in accordance with generally 

accepted government auditing standards.

Selected administrative requirements in OMB’s government-wide grant 

guidance generally focus on protecting against waste, fraud, and abuse of 

funds; in contrast, the requirements in agency-specific guidance generally 

focus on promoting the quality and effectiveness of federally funded 

research. Selected universities and stakeholder organizations identified 

the following common factors that add to their administrative workload 

and costs for complying with the requirements: (1) variation in funding 

agencies’ implementation of requirements, (2) development of grant 

proposal documentation at a stage when details of a research project 

remain uncertain, and (3) recent policy reforms that resulted in certain 

requirements becoming more prescriptive. OMB and funding agencies’

streamlining efforts resulted in some reductions to universities’

administrative workload and costs for complying with selected 

requirements, but these reductions were limited.

Selected administrative requirements in the Uniform Guidance, OMB’s 

government-wide grant guidance, generally focus on protecting against 

waste, fraud, and abuse of funds, as we found in our June 2016 report. 

These include requirements related to competition and documentation of 

purchases, documentation of personnel expenses, and preparation and 

management of project budgets. For example, funding agencies 

implement Uniform Guidance requirements for budget preparation and 

management by designing agency-specific forms and processes to 

review applicants’ requests for funding and grantees’ use of funding. 

These requirements allow for identification of questionable requests for 

funding in applications and unallowable post-award charges to grants.

In contrast, selected administrative requirements in agency-specific 

guidance generally focus on promoting the quality and effectiveness of 

federally funded research. Specifically, funding agencies have 

established administrative requirements to promote the selection and 

development of qualified researchers, protect against bias in the conduct 

of research, and improve access to research data and results. For 

example, since 1995, NIH-funded researchers have been subject to 

Department of Health and Human Services (HHS) financial conflict of 

interest regulations designed to promote objectivity. NASA and NSF have 

also implemented financial conflict of interest requirements to help protect 

Summary

Selected 

Requirements Govern 

the Proper Use of 

Grant Funds and 

Research Quality and 

Effectiveness
Page 4 GAO-16-890T 

against bias in the conduct of research, and DOE was in the process of 

establishing such requirements as of June 2016.

In our June 2016 report, we found that selected universities and 

stakeholder organizations identified common factors that add to their 

administrative workload and costs for complying with selected 

requirements. First, at all six universities, officials told us that variation in 

funding agencies’ implementation of certain administrative requirements 

contributes to workload and costs because, for example, universities have 

to design and implement multiple processes and may need to invest in 

electronic systems to comply with agencies’ requirements. Officials we 

interviewed cited variation in three categories of requirements in 

particular: developing and submitting biographical sketches describing 

researchers’ professional accomplishments; identifying, reporting, and 

managing financial conflicts of interest; and preparing and managing 

project budgets. For example, agency implementation of budget 

preparation and management requirements differs in several ways, 

including the forms and level of detail required in proposed budgets and 

the systems for grantee financial reporting.

A second factor, according to university officials we interviewed, is the 

workload and costs of developing grant proposal documentation. To help 

select proposals for funding, funding agencies require researchers to 

prepare detailed documentation—including proposed project budgets, 

data management plans, and in some cases information on conflicts of 

interest—as part of the application process. Given recent proposal 

funding rates, the likelihood of an agency selecting a proposal for funding 

is relatively low. For example, in fiscal year 2015, NIH awarded funding to 

18 percent of applicants, and NSF awarded funding to 24 percent of 

applicants—rates similar to those of other years. As a result, for most 

proposals, universities’ investments of time and resources do not result in 

research funding. Furthermore, researchers and administrative staff we 

interviewed said that during the pre-award stage, there can be a relatively 

high level of uncertainty about specific details of a research project, 

including budget details about potential vendors or travel costs and 

details about expected research data and results. They said that 

complying with requirements to prepare and submit documents at a stage 

when these details remain uncertain is not an efficient use of time.

Finally, recent OMB and HHS policy reforms resulted in changes to 

selected requirements that, according to university officials, made them 

more prescriptive and added to administrative workload and costs. 

Selected Universities 

Identified Common 

Factors That Add to 

Their Workload and 

Costs for Complying 

with Selected 

Administrative 

Requirements
Page 5 GAO-16-890T 

Specifically, the Uniform Guidance includes revised requirements for 

competition and documentation of purchases that are more prescriptive 

than those in OMB’s prior circular that applied to universities.6In addition, 

in 2011, HHS revised regulations governing financial conflicts of 

interest—which apply to research funded by NIH—to address concerns 

about the objectivity of the research HHS funds. These revisions included 

more prescriptive requirements for, among other things, the types of 

financial interests researchers must disclose. Officials at universities in 

our review stated that the more prescriptive requirements add to 

universities’ workload and costs in several ways. For example, officials at 

all six universities told us that they expect the new purchasing competition 

and documentation requirements—particularly the lower threshold at 

which price or rate quotations must be obtained from multiple vendors—

will result in added costs for updating their electronic purchasing 

systems.7 More specifically, officials at five of the universities in our 

review told us that, prior to the Uniform Guidance, their thresholds for 

obtaining multiple quotations had been higher than the threshold in the 

Uniform Guidance, and that they will now need to obtain multiple 

quotations for more transactions than before.

 

6Stakeholder organizations raised concerns to OMB about increased administrative 

workload and costs resulting from its revised purchasing requirements, and OMB delayed 

implementation of the new requirements for 2 full fiscal years after the effective date of the 

Uniform Guidance. The revised purchasing requirements will become effective for 

universities sometime in 2017, depending on universities’ fiscal calendars.

7The Uniform Guidance establishes five methods for purchasing goods or services. One 

of these methods, procurement by micropurchases, applies to purchases under $3,500 

and does not require soliciting competitive quotations if the grantee considers the price to 

be reasonable. The Uniform Guidance defines the micropurchase threshold as the 

threshold set by the Federal Acquisition Regulation at 48 C.F.R. Subpart 2.1 (Definitions). 

When the Uniform Guidance was issued, the threshold was $3,000 except as otherwise 

discussed in Subpart 2.1 of that regulation, but it is periodically adjusted for inflation. See 

2 C.F.R. § 200.67. At the time of our June 2016 report, the threshold was $3,500. 

Purchases that exceed this threshold trigger additional requirements for providing full and 

open competition, such as obtaining price or rate quotations from an adequate number of 

qualified sources. 
Page 6 GAO-16-890T 

OMB and the four research funding agencies in our June 2016 report 

have made continuing efforts to reduce universities’ administrative 

workload and costs for complying with selected requirements. These 

efforts include (1) standardizing requirements across agencies, (2) 

streamlining pre-award requirements, and (3) in some cases allowing 

universities more flexibility to assess and manage risks for some 

requirements. In each of these areas, OMB and agency efforts resulted in 

some reductions to administrative workload and costs, but these 

reductions were limited. We made recommendations in our June 2016 

report that agencies make further improvements in each area. DOE, 

NASA, and NIH generally concurred, and OMB and NSF did not comment 

on the recommendations.

In accordance with federal goals for standardization, OMB led several 

efforts to standardize selected requirements, primarily those related to 

budget preparation and management. For example, OMB’s Uniform 

Guidance established standard requirements for financial management of 

federal awards and generally requires the use of OMB-approved 

government-wide standard forms for reporting financial and performance 

information. Funding agencies made similar efforts to standardize 

requirements through the Office of Science and Technology Policy’s 

(OSTP) Research Business Models working group (RBM)—an 

interagency group that consists of officials from DOE, NASA, NIH, NSF, 

and other federal research funding agencies. RBM’s charter calls for it to 

examine opportunities and develop options to unify agency research 

grants administration practices and to assess and report periodically on 

the status, efficiency, and performance of the federal-academic research 

partnership. However, neither OMB nor funding agency efforts to 

standardize requirements fully addressed the variations in requirements, 

thereby limiting the potential reductions in universities’ administrative 

workload and costs. For example, the Uniform Guidance does not prohibit 

agencies from varying in how they implement aspects of budget 

preparation and management requirements, such as the forms and level 

of detail required in proposed budgets, agency systems for financial 

reporting, or the budget revisions agencies allow grantees to make 

without obtaining prior approval. Similarly, RBM’s efforts to standardize 

research terms and conditions allow for agency-specific exceptions. Also, 

RBM’s efforts have primarily focused on post-award requirements, and it 

has not initiated a process to standardize pre-award requirements.

According to OMB staff and funding agency officials, several factors can 

limit agencies’ ability to standardize administrative requirements on 

OMB and Funding 

Agencies Have Made 

Continuing Efforts to 

Reduce Universities’

Administrative 

Workload and Costs, 

with Limited Results

Standardizing 

Administrative 

Requirements
Page 7 GAO-16-890T 

research grants. For example, funding agencies must comply with 

differing statutory or other requirements, which can result in differences in 

their requirements for grantees. There are also differences in the types of 

research or recipients that agencies fund that can limit their ability to 

standardize requirements. Nevertheless, agencies have opportunities to 

standardize requirements to a greater extent than they have already 

done. In particular, they have flexibility in how they implement aspects of 

selected requirements that are not subject to statutory or other 

requirements or to agency-specific differences in types of research or 

recipients. According to some funding agency officials we interviewed, 

aspects of requirements for which agencies have such flexibility include 

the format and content of biographical sketches, the budget forms and 

content of budget justifications that agencies require in applications, and 

the types of budget revisions agencies allow grantees to make without 

obtaining prior approval. Officials at NSF, NIH, and OSTP who co-chair 

RBM told us that the group is well suited to pursue further standardization 

efforts and to report on them. Such efforts could help agencies reduce 

universities’ administrative workload and costs and improve their 

oversight of funding and support of research quality. Accordingly, in our 

June 2016 report, we recommended that DOE, NASA, HHS, and NSF 

coordinate through RBM to identify additional areas where they can 

standardize requirements, and to report on these efforts. DOE, NASA, 

and HHS generally agreed with this recommendation and said they would 

continue to build on RBM’s previous efforts, and NSF did not formally 

comment on the recommendation.

DOE, NASA, NIH, and NSF have made efforts to streamline 

administrative requirements associated with proposal preparation by 

allowing applicants to postpone their submission of certain documentation 

until after a preliminary decision about an their likelihood of obtaining 

funding. Under these efforts, applicants are required to provide only a 

limited set of application materials—often referred to as a preliminary 

proposal—for initial evaluation before possible submission of a full 

proposal. Preliminary proposals are intended, in part, to reduce 

applicants’ administrative workload and costs when applicants’ chances 

of success are very small. Such efforts are in line with RBM’s charter, 

which calls for agencies to identify approaches to streamline 

administration practices for research grants. The funding agencies in our 

review use a range of preliminary proposal processes, which can allow 

applicants to postpone submitting documentation related to budget 

preparation, biographical sketches, and developing plans to manage and 

share research data and to mentor researchers. According to university 

Streamlining Pre-Award 

Requirements
Page 8 GAO-16-890T 

officials, stakeholder organizations, and information from the four funding 

agencies in our review, efforts to defer certain pre-award requirements 

generally have led to reductions in universities’ administrative workload 

and costs. For example, one NSF division evaluated its preliminary 

proposal pilot in 2014 and reported that the pilot led to reduced applicant 

workload by lessening the number of proposal pages researchers needed 

to write and simplifying the documents university administrative offices 

required, since preliminary proposals do not include budgets.

Preliminary proposals may not be effective in reducing administrative 

workload and costs for certain solicitations or grant programs, such as 

specialized grants for which a small number of scientists are likely to 

apply, according to agency officials. Nevertheless, agencies have not 

extended pre-award streamlining efforts to all grant solicitations for which 

they could be used to reduce workload and costs. In certain instances, 

agencies still require documentation they may not need to effectively 

evaluate initial proposals. For instance, NIH does not generally allow 

applicants to defer submitting documentation for proposed budgets, 

biographical sketches, or other requirements that other agencies have 

determined are not necessary for preliminary proposals. In addition, preaward streamlining efforts at DOE, NASA, and NSF are limited to certain 

offices or certain programs within the agencies, in some cases because 

the efforts are still in pilot phases.

We found in our June 2016 report that NSF had taken steps to expand its 

use of preliminary proposals and that opportunities remain for other 

agencies to do so as well. Specifically, in 2015, NSF senior leadership 

directed officials from NSF’s directorates to review and identify options to 

reduce researchers’ administrative workload and costs, including by 

expanding use of preliminary proposals and focusing application reviews 

on a minimum set of elements needed to meet NSF’s merit review 

criteria.8 As a result of the directive, three NSF directorates expanded 

 

8NSF took these steps partly in response to the National Science Board’s 2014 

recommendations to reduce administrative workload by expanding the use of preliminary 

proposals or just-in-time submissions. See National Science Board, Reducing 

Investigators’ Administrative Workload for Federally Funded Research, NSB-14-18 (Mar. 

10, 2014). The National Science Board establishes the policies of NSF within the policy 

framework set forth by the President and Congress and serves as an independent policy 

advisory body to the President and Congress on science and engineering research and 

education issues. 
Page 9 GAO-16-890T 

their use of preliminary proposals, for instance, by allowing applicants to 

postpone submitting detailed budgets until proposals are recommended 

for award. DOE, NASA, and NIH have not conducted similar agency-wide 

reviews to identify opportunities for expanded use of preliminary 

proposals or just-in-time submissions.9 As a result, we recommended that 

these three agencies conduct agency-wide reviews of possible actions, 

such as further use of preliminary proposals, to postpone pre-award 

requirements until after a preliminary decision about an applicant’s 

likelihood of funding. Such reviews may help ensure that agencies do not 

miss opportunities to reduce unnecessary pre-award administrative 

workload and costs for applicants that do not receive awards. DOE, HHS, 

and NASA generally concurred with this recommendation.

OMB and funding agencies have made efforts, in accordance with federal 

goals, to reduce administrative workload and costs by allowing 

universities more flexibility to assess and manage risks related to certain 

administrative requirements. One of OMB’s stated objectives for its 

reforms in the Uniform Guidance was “focusing on performance over 

compliance for accountability,” for instance, by allowing recipients of 

federal awards the flexibility to devote more effort to achieving 

programmatic objectives rather than to complying with complex 

requirements. Efforts by OMB and the funding agencies in our review to 

allow universities more flexibility to assess and manage risks related to 

administrative requirements—particularly requirements for budget 

preparation and management and documenting personnel expenses—

have led to reductions in administrative workload and costs, according to 

officials from the four funding agencies and six universities in our review. 

For example, in the Uniform Guidance, OMB modified requirements for 

documenting personnel expenses to focus on establishing standards for 

recipients’ internal controls over salary and wage expenses, without 

prescribing procedures grantees must use to meet the standards. 

Officials from the two universities in our review that piloted streamlined 

 

9

In commenting on a draft of our June 2016 report, HHS stated that in 2014, NIH 

commissioned an evaluation to recommend ways to further optimize the process of 

reviewing, awarding, and managing grants and to maximize the time researchers can 

devote to research. The resulting report also found that the use of preliminary proposals 

could be expanded and included a recommendation that NIH pilot test preliminary 

proposals. NIH, Scientific Management Review Board, Report on Streamlining the NIH 

Grant Review, Award, and Management Process (July 2015). 

Allowing Universities More 

Flexibility
Page 10 GAO-16-890T 

methods for documenting salary and wage charges to federal awards 

said these pilots resulted in over an 80-percent reduction in the number of 

forms that principal investigators needed to review and corresponding 

reductions in time needed to develop and process these forms, as well as 

reductions in the time and costs of training staff.

In contrast, several administrative requirements—including OMB 

requirements related to purchases and NIH requirements related to 

financial conflicts of interest—limit universities’ flexibility and require them 

to allocate administrative resources toward oversight of lower-risk 

purchases and financial interests. First, in developing the Uniform 

Guidance, OMB based the micro-purchase threshold—above which 

grantees must generally obtain price or rate quotations, competitive bids, 

or competitive proposals—on the threshold for competition of purchases 

made under federal contracts. Officials from all six universities in our 

review said that for relatively small purchases that exceed the threshold, 

the administrative workload and costs associated with competition may 

outweigh the savings gained. Second, under the 2011 revised HHS 

regulations governing NIH’s conflict of interest requirements, researchers 

must disclose to their institution a range of financial interests held by 

them, their spouses, and their dependent children. University and 

stakeholder organization officials we interviewed generally agreed that 

the additional financial interests that must be disclosed and reviewed 

under the revised requirements—particularly reimbursed or sponsored 

travel costs, which officials said are common among academic 

researchers—rarely result in identification of actual conflicts that could 

bias their research.

Both OMB and HHS plan to evaluate their revised guidance and 

regulation, respectively. Since issuing these rules, OMB and HHS, as well 

as stakeholder organizations, have begun collecting information on the 

effects of the rules that the agencies can use in their evaluations. For 

example, OMB directed agencies to report, beginning in January 2015, 

information on their implementation of the Uniform Guidance, including 

metrics on the overall impact on burden and waste, fraud, and abuse.10

The additional information could allow OMB and HHS to more fully 

 

10Office of Management and Budget, Metrics for Uniform Guidance (2 C.F.R. 200), OMB 

Memorandum M-14-17 (Washington, D.C.: Sept. 30, 2014).
Page 11 GAO-16-890T 

consider the requirements’ effects on universities’ administrative workload 

and costs and balance such considerations against the requirements’

added protections for accountability and research integrity. Accordingly, 

we recommended that HHS, as part of the planned evaluation of its 

regulation governing financial conflicts of interest in NIH-funded research, 

evaluate options for targeting requirements on areas of greatest risk for 

researcher conflicts, including adjusting the threshold and types of 

financial interests that need to be disclosed. HHS concurred and stated in 

its comments on our draft report that it plans to measure the effectiveness 

of the financial conflict of interest requirements and identify areas that 

may create administrative burden. Similarly, we recommended that OMB, 

as part of its planned evaluation of the Uniform Guidance, evaluate 

options for targeting requirements for research grants to universities. 

OMB did not formally state whether it concurred with this 

recommendation, but OMB staff told us that they agree that opportunities 

remain for streamlining administrative requirements.

Chairwoman Comstock, Ranking Member Lipinski, and Members of the 

Subcommittee, this completes my prepared statement. I would be 

pleased to respond to any questions that you may have at this time.

If you or your staff members have any questions concerning this 

testimony, please contact me at (202) 512-3841 or neumannj@gao.gov. 

Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this statement. Other individuals 

who made key contributions to this testimony include Joseph Cook, 

Assistant Director, and Miles Ingram.

GAO Contact and 

Staff 

Acknowledgments

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