Accessible Version

FEDERAL

RESEARCH 

OPPORTUNITIES

DOE, DOD, and HHS 

Need Better Guidance 

for Participant 

Activities

Report to the Ranking Member, 

Permanent Subcommittee on 

Investigations, Committee on Homeland 

Security and Governmental Affairs, U.S. 

Senate

January 2016

GAO-16-128

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-128, a report to the 

Ranking Member, Permanent Subcommittee 

on Investigations, Committee on Homeland 

Security and Governmental Affairs, U.S. 

Senate

January 2016

FEDERAL RESEARCH OPPORTUNITIES

DOE, DOD, and HHS Need Better Guidance for 

Participant Activities

Why GAO Did This Study

The ORISE research participation 

program seeks to enhance the future 

scientific and engineering workforce by 

providing students, postgraduates, and 

faculty with hands-on research 

experiences in federal agencies. The 

program is administered by a DOE 

contractor, and other agencies sponsor 

research participants via interagency 

agreements with DOE. Research 

participants engage in a variety of 

projects at DOE and other sponsoring 

agencies, but they are not considered 

federal government employees and 

thus are prohibited from performing 

inherently governmental functions.

GAO was asked to review the ORISE 

research participation program. This 

report examines (1) program 

expenditures by all sponsoring 

agencies and (2) selected agencies’ 

assessments of program effectiveness 

and their guidance on inherently 

governmental functions.

GAO reviewed program data for fiscal 

years 2010-2014, the five most recent 

years for which data were available; 

examined program policies and 

guidance at DOE, DOD, and HHS, the 

three agencies that sponsored the 

most participants in fiscal year 2014; 

and interviewed officials at those three 

agencies.

What GAO Recommends

GAO recommends that DOE, DOD, 

and HHS develop detailed guidance to 

inform their employees and research 

participants about inherently 

governmental functions. DOE, DOD, 

and HHS concurred with the 

recommendation and said they will 

take additional measures to provide 

detailed guidance to relevant parties.

What GAO Found

For fiscal years 2010 through 2014, the 11 departments and other federal 

agencies that sponsor research participants collectively expended $776.4 million 

for activities carried out through the Oak Ridge Institute for Science and 

Education (ORISE) research participation program (ORISE program). The three 

agencies with the highest expenditures for the program over the 5-year period 

were the Department of Energy (DOE), which oversees the contractor managing

ORISE, and the Department of Defense (DOD) and Department of Health and 

Human Services (HHS), which both sponsor research participants via 

interagency agreements with DOE. Expenditures increased 73 percent over that 

period, and the number of appointments increased 42 percent. Stipends 

accounted for 82 percent of expenditures over that period, with the remainder 

going to other participant expenses, overhead and program support, and 

administrative and security charges. Agencies’ expenditures per appointment 

varied for several reasons, such as differences in methods of setting stipends.

Components within DOE, DOD, and HHS that sponsor research participants 

have performed some assessments of the short-term effectiveness of the ORISE 

program, but provide varying levels of detail to agencies’ employees and 

research participants about inherently governmental functions—those functions 

that are so intimately related to the public interest as to require performance by 

federal government employees.

· Program effectiveness. Sponsoring agency components establish their 

own objectives for research participants and can decide whether and 

how to assess the extent to which the ORISE program meets those 

objectives. DOE, DOD, and HHS components have used questionnaires 

and other methods to assess how well the ORISE program meets the 

short-term needs of research participants and of the agency staff who 

oversee their activities. Agencies also face challenges in assessing the 

program’s long-term effectiveness; for example, they do not have 

methods to track research participants over their careers to determine 

the extent to which participants’ success is a result of the program. DOE 

has worked with other agencies on developing ways to address such 

challenges.

· Inherently governmental functions. Federal guidance directs agencies 

to develop internal procedures to ensure that only federal employees 

perform inherently governmental functions. DOE, DOD, and HHS 

sponsoring components’ guidance for research participants that GAO 

reviewed had varying levels of detail on inherently governmental 

functions. Officials at these agencies said that research participants’ 

projects generally do not involve inherently governmental functions, but 

GAO found that some research participants’ projects involve activities 

that are closely associated with inherently governmental functions, such 

as participating in certain policy and strategic planning meetings, which 

may increase the risk of the participants performing inherently 

governmental functions. Development of detailed guidance could help 

sponsoring components reduce this risk and help officials better ensure 

adherence to the federal guidance on inherently governmental functions.

View GAO-16-128. For more information, 

contact John Neumann at (202) 512-3841 or 

neumannj@gao.gov.
Letter 1

Page i GAO-16-128 Federal Research Opportunities 

Background 6

Agency Expenditures for the ORISE Program Increased from 

2010 through 2014, with Stipends Making Up the Largest 

Portion of Expenses 7

Assessment of the ORISE Program and Guidance on Inherently 

Governmental Functions Varies Among Sponsoring Agency 

Components 14

Conclusions 19

Recommendation for Executive Action 20

Agency Comments and Our Evaluation 20

Appendix I: Examples of Subject Areas for ORISE Research Participant Projects in Fiscal Year 2014 22

Appendix II: Federal Expenditures for and Appointments in the ORISE Research Participation Program 23

Appendix III: Comments from the Department of Energy 28

Appendix IV: Comments from the Department of Defense 30

Appendix V: Comments from the Department of Health and Human Services 32

Appendix VI: GAO Contact and Staff Acknowledgments 34

GAO Contact 34

Staff Acknowledgments 34

Appendix VII: Accessible Data 35

Agency Comment 35

Letter 35

Data Tables 39

Tables

Table 1: Federal Agency Expenditures for the Oak Ridge Institute for 

Science and Education (ORISE) Research Participation 

Program, Fiscal Years 2010-2014 23

Table 2: Federal Appointments in the Oak Ridge Institute for Science 

and Education (ORISE) Research Participation Program by 

Agency, Fiscal Years 2010-2014 24

Contents
Table 3: Federal Agency Total Expenditures for the Oak Ridge Institute 

for Science and Education (ORISE) Research Participation 

Program by Type of Expense, Fiscal Years 2010-2014 25

Data Table for Figure 1: Agency Expenditures (Fiscal Years 2010-2014) 

and Appointments (Fiscal Year 2014) for the Oak Ridge 

Institute for Science and Education Research Participation 

Program 39

Data Table for Figure 2: Total Expenditures and Appointments for the 

Oak Ridge Institute for Science and Education Research 

Participation Program, Fiscal Years 2010-2014 40

Data Table for Figure 3: Agency Expenditures for the Oak Ridge 

Institute for Science and Education (ORISE) Research 

Participation Program by Type of Expense, Fiscal Years 2010-

201441

Figures

Page ii GAO-16-128 Federal Research Opportunities 

Figure 1: Agency Expenditures (Fiscal Years 2010-2014) and 

Appointments (Fiscal Year 2014) for the Oak Ridge Institute 

for Science and Education Research Participation Program 8

Figure 2: Total Expenditures and Appointments for the Oak Ridge 

Institute for Science and Education Research Participation 

Program, Fiscal Years 2010-2014 9

Figure 3: Agency Expenditures for the Oak Ridge Institute for Science 

and Education (ORISE) Research Participation Program by 

Type of Expense, Fiscal Years 2010-2014 12
Page iii GAO-16-128 Federal Research Opportunities 

Abbreviations

APSS Applicant and Participant Status System

CDC Centers for Disease Control and Prevention

DOD Department of Defense

DOE Department of Energy

FDA Food and Drug Administration

HHS Department of Health and Human Services

OMB Office of Management and Budget

ORAU Oak Ridge Associated Universities

ORISE Oak Ridge Institute for Science and Education

ORISE program ORISE research participation program

PIES Program Information Entry System

STARS Standard Accounting and Reporting System

STEM science, technology, engineering, and mathematics

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-16-128 Federal Research Opportunities 

441 G St. N.W.

Washington, DC 20548

January 20, 2016

The Honorable Claire McCaskill

Ranking Member

Permanent Subcommittee on Investigations

Committee on Homeland Security and Governmental Affairs

United States Senate

Dear Senator McCaskill:

Federal agencies manage an investment of about $3 billion annually in 

science, technology, engineering, and mathematics (STEM) education 

programs to help prepare students and teachers for careers in STEM 

fields and to enhance the nation’s global competitiveness. As part of this 

investment, the U.S. Department of Energy (DOE) has awarded a 

contract to the nonprofit Oak Ridge Associated Universities (ORAU) to 

manage and direct the programs of the Oak Ridge Institute for Science 

Education (ORISE) in Oak Ridge, Tennessee. Among other things, the 

contractor manages the ORISE research participation program (ORISE 

program) to develop the STEM workforce by providing hands-on research 

experiences at DOE for students, postgraduates, and faculty.1In addition, 

the contractor administers the ORISE program for other federal agencies that 

have entered into interagency agreements with DOE for the program. 

Students and postgraduates in the ORISE program at DOE and other 

federal agencies engage in activities that complement their academic 

programs, while faculty members learn state-of-the-art science that they 

can incorporate into their teaching. These participants obtain research 

experiences in various locations at federal agencies, such as

 

1ORAU administers separate and customized research participation programs for a variety of 

federal sponsors. For ease of reference, this report refers to the portfolio of such programs 

administered by ORAU for research participants as the ORISE program and is not meant 

to imply that ORISE administers a single program in which all the agencies participate. 

The scope of this report is limited to the ORISE program’s nonemployee research 

participants at federal agencies. References in this report to the ORISE program do not 

include research participants treated by the program as employees or research 

participants at nonfederal entities, such as the Nature Conservancy. 

Letter
departmental offices, research centers and institutes, or military units and 

commands.

Page 2 GAO-16-128 Federal Research Opportunities 

2

In fiscal year 2014, ORAU administered close to 5,900 ORISE research 

participant appointments on behalf of DOE and other federal agencies, 

including the Department of Defense (DOD) and the Department of 

Health and Human Services (HHS). Sponsoring agencies—DOE, DOD, 

HHS, and other agencies that sponsor ORISE research participants—use 

their respective budgetary resources to fund the research participants.

Components within sponsoring agencies assign research participants in 

the ORISE program (ORISE research participants) to various research 

projects. For example, DOE sponsors research participants in the Office 

of Science, as well as in other components within DOE. Other federal 

agencies with components interested in sponsoring research participants 

can enter into interagency agreements—known as Strategic Partnership 

Projects agreements—with DOE.3 These agreements permit DOE, through 

ORAU, to administer the ORISE program for other federal agencies on a 

reimbursable basis. The agreements provide for the sponsoring agencies to pay 

DOE for the cost of the ORISE program at the sponsoring agencies and 

for specified administrative costs.

ORAU and sponsoring agencies each have specific responsibilities for 

the ORISE program. Pursuant to ORAU’s contract with DOE and DOE’s 

interagency agreements (including statements of work) with other 

sponsoring agencies, ORAU provides support services, such as handling 

administrative activities related to participant’s stipends and travel 

reimbursements. Sponsoring agency components perform other tasks, 

such as selecting participants, providing project descriptions, and 

 

2

In fiscal year 2014, sponsoring agencies included the Department of Agriculture; Federal Bureau 

of Investigation; DOD, and within the department, the Air Force, Army, and Navy; HHS, and 

within the department, Centers for Disease Control and Prevention, Food and Drug 

Administration, and National Institutes of Health; Department of Homeland Security; 

Department of Housing and Urban Development; Department of State; Department of the 

Interior; and Environmental Protection Agency. 

3These interagency agreements were known as Work for Others agreements until March 9, 2015, 

when DOE renamed them Strategic Partnership Projects. Department of Energy, Strategic 

Partnership Projects Order 481.1C, chg 2 (March 9, 2015). For more information on 

Strategic Partnership Agreements, see GAO, National Laboratories: DOE Needs to 

Improve Oversight of Work Performed for Non-DOE Entities, GAO-14-78 (Washington, 

D.C.: Oct. 25, 2013). 
designating coordinators to manage research participants’ overall 

participation in the program and mentors to direct research participants’ 

day-to-day activities.

As with all nonfederal employees, ORISE research participants are 

prohibited from performing inherently governmental functions—functions 

within the federal government that are so intimately related to the public 

interest as to require performance by government employees. This 

prohibition ensures that the act of governance is performed, and 

decisions of significant public interest are made, by officials who are 

accountable to the President and bound by laws controlling the conduct 

and performance of federal employees that are intended to protect or 

benefit the public and ensure the proper use of appropriated funds.

Page 3 GAO-16-128 Federal Research Opportunities 

4

Inherently governmental functions include activities that require either the 

exercise of discretion in applying federal government authority or the making of 

value judgments in making decisions for the federal government.5

Guidance issued by the Office of Management and Budget’s (OMB) Office of 

Federal Procurement Policy regarding the performance of inherently 

governmental functions directs agencies to develop agency-level procedures, 

provide training, and designate senior officials to be responsible for 

implementing policies on inherently governmental functions.6

You asked us to review the ORISE program, including expenditures. This 

report examines (1) expenditures for the ORISE program by all 

sponsoring agencies and (2) selected agencies’ assessments of the 

ORISE program’s effectiveness, and their guidance on ensuring research 

participants do not perform inherently governmental functions.

To examine federal agency expenditures for the ORISE program, we 

reviewed data on ORISE program overhead, stipend, and other research 

participant expenditures and on the number of appointments for fiscal 

years 2010 through 2014, the most recent years for which data were 

 

4

76 Fed. Reg. 56227, 56236 (Sept. 12, 2011). 

5

Pub. L. No. 105-270, § 5(2)(B), 112 Stat. 2382, 2384-85 (1998).

6The Office of Management and Budget issued a policy letter providing guidance on 

managing the performance of inherently governmental and critical functions pursuant to a 

mandate in section 321 of the Duncan Hunter National Defense Authorization Act for 

Fiscal Year 2009 (Pub. L. No. 110-417, § 321, 122 Stat. 4356, 4411 (2008)), 76 Fed. Reg. 

56227, 56228 (Sept. 12, 2011).
available. ORAU officials compiled this data from three databases: (1) 

ORAU’s Program Information Entry System (PIES)/Applicant and 

Participant Status System (APSS), for information on appointments for 

fiscal years 2010 through 2014; (2) ORAU’s Oracle financial system, for 

expenditure data for fiscal years 2010 through 2014, including federal 

administrative charge data for fiscal years 2013 and 2014; and (3) DOE’s 

Standard Accounting and Reporting System (STARS), for federal 

administrative charge data for fiscal years 2010 through 2012.

Page 4 GAO-16-128 Federal Research Opportunities 

7 We 

assessed the reliability of the data by interviewing ORAU officials regarding the 

systems from which they obtained the data and their data collection and 

verification practices, reviewing documentation of audits, reviewing other 

reports on the data, and manually testing the internal consistency of the 

data; we determined that the data were sufficiently reliable for the 

purpose of reporting on program expenditures and numbers of 

appointments. To identify how sponsoring agency components 

determined stipends and other expenses for research participants, we 

reviewed agency components’ guidance; for further detail, we requested 

responses to a standard set of questions from officials at selected DOE, 

DOD, and HHS components that sponsor research participants. We 

analyzed the data to determine expenditures per appointment at DOE 

and other sponsoring agencies and to analyze program statistics and 

trends, and we interviewed ORAU officials and officials at sponsoring 

agency components to determine the factors that affect expenditures per 

appointment.

To examine agency assessments of the ORISE program’s effectiveness 

and agency guidance on inherently governmental functions, we focused 

on DOE, DOD, and HHS because these three agencies were the largest 

sponsors of research participants in terms of numbers of appointments 

and amount of expenditures in 2014.8 We examined relevant statutes, 

contracts, and agreements to obtain a general understanding of DOE, DOD, and 

HHS responsibilities for assessing the ORISE program and for ensuring the 

prohibition on nonfederal employees performing inherently governmental 

functions is being followed. These documents included ORAU’s contract 

 

7According to DOE officials, section 3137 of the Strom Thurmond National Defense Authorization 

Act for Fiscal Year 1999 requires DOE to impose a federal administrative charge on agencies 

with ORISE research participants. 

8

Sponsoring agencies expended around $194 million for ORISE program activities in fiscal year 

2014. DOE, DOD, and HHS, the sponsoring agencies in our review, accounted for over 88 

percent of appointments and over 87 percent of program expenditures in fiscal year 2014. 
with DOE and the Economy Act of 1932, as amended. In addition, we 

examined documents developed by ORAU and used by DOE, DOD, and 

HHS to set forth the terms governing research participant appointments. 

In particular, we examined examples of statements of work, research 

participant appointment letters, and terms of appointments to determine 

the extent to which they included information or guidance on inherently 

governmental functions. In addition, we reviewed websites for the ORISE 

program, as well as other documents, such as participant handbooks, that 

ORAU and sponsoring agency officials provided to us. We interviewed 

ORAU officials, as well as officials at a nongeneralizable sample of 27 

DOE, DOD, and HHS components involved with the program (including 

program coordinators and mentors at sponsoring agency components) 

and requested responses to a standard set of questions from the 27 

components to determine how they manage and assess the effectiveness 

of their program and how they ensure the prohibition on inherently 

governmental activities is being followed.

Page 5 GAO-16-128 Federal Research Opportunities 

9 We selected the 27 sponsoring 

agency components by using data on the number of all research 

participant appointments at DOE, DOD, and HHS in fiscal year 2014. In 

particular, we selected components that had both relatively large and 

small numbers of research participants and that, in total, represented over 

half of all federal agency research participant appointments in fiscal year 

2014. As part of interviews with these components, we also requested 

written guidance related to those aspects we examined, including 

inherently governmental functions. We also reviewed questionnaires that 

sponsoring agency components administered to research participants 

and interviewed ORAU and agency component officials involved with the 

program to determine how questionnaires were used to assess the 

effectiveness of the ORISE program.

For general context on the types of projects sponsoring agency 

components assigned research participants to, we interviewed two 

research participants and two mentors about their experiences with the 

program. In addition, we obtained examples of research participant 

project subject areas from ORAU officials.

 

9The 27 agency components fell within 10 entities: DOE’s Office of Science, Office of Energy 

Efficiency and Renewable Energy, and Oak Ridge National Laboratory; HHS’s Centers for 

Disease Control and Prevention, Food and Drug Administration, and National Library of 

Medicine of the National Institutes of Health; and DOD’s Office of the Under Secretary of 

Defense for Acquisition, Technology, and Logistics, and components within the Army, Air 

Force, and Navy. 
We conducted this performance audit from November 2014 to January 

2016 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

The purpose of DOE’s contract with ORAU is to provide management and 

direction of programs through ORISE that maintain and advance science 

and education capabilities supporting DOE’s strategic goals in the areas 

of defense, energy, science, and the environment. To support these 

goals, ORAU carries out a range of activities for DOE, including 

administering workforce development programs to help ensure the future 

availability of scientists and engineers. These workforce development 

programs are intended to encourage individuals to enter STEM careers, 

complement students’ academic programs, and provide faculty with stateof-the-art information to use in the classroom, as well as developing a 

pool of talent from which federal agencies can draw for future 

employment. ORAU groups its workforce development activities into the 

following three categories:

· Research participation program: This program provides research 

experiences to students, postgraduates, faculty, and other 

participants. These activities make up the ORISE program.

Page 6 GAO-16-128 Federal Research Opportunities 

10

· Fellowships and scholarships: Among other things, these programs 

provide financial assistance for students to obtain academic degrees 

in areas related to the sponsoring agency’s mission.

· Events, academies, and competitions: These programs, such as 

the National Science Bowl, a nationwide middle- and high-school 

science and mathematics competition, are designed to encourage 

participation in scientific and technological fields.

 

10As part of the ORISE program, ORAU administers some programs that sponsoring agencies call 

fellowships, such as the Albert Einstein Distinguished Educator Fellowship program within the 

DOE Office of Science.

Background
In fiscal year 2014, most of the federal agency expenditures on workforce 

development activities administered by ORAU were for the ORISE 

program. In that year, federal agencies expended $193.8 million on the 

ORISE program, followed by $3.2 million for fellowships and scholarships, 

and $1.7 million for events, academies, and competitions. These 

expenditures supported 5,854 research participation appointments, 72 

scholarships and fellowships, and 1,191 special event participants.

ORISE research participants engage in a variety of subject areas, such 

as climate change, weather impacts on military projects, infectious and 

chronic diseases, computer simulations of potential terrorist attacks or 

natural disasters, and conservation measures for fish and wildlife. (See 

app.I for additional examples, by sponsoring agency, of project subject 

areas in fiscal year 2014.) Research participants may also be involved in 

developing briefing materials on their research for agency leadership, 

publishing the results of their research, participating in conferences, and 

obtaining other research-related experiences. Research participants are 

not considered federal employees or federal contractors and do not 

receive a salary. They instead receive stipends and certain other 

expenses to defray their costs of living during their appointments. 

Participant appointments can be full- or part-time and can last for weeks, 

such as in the case of a 10- to 12-week summer program, or years, such 

as in the case of a 1-year postgraduate program renewable for up to 4 

additional years.

From fiscal year 2010 through fiscal year 2014, DOE and other 

sponsoring agencies expended a total of $776.4 million for the ORISE 

program, with DOD, DOE, and HHS accounting for the majority of the 

expenditures. Over that period, annual program expenditures increased 

by 73 percent, and the number of annual appointments rose by 42 

percent. Stipends accounted for the largest portion of agencies’ 

expenditures. Sponsoring agency expenditures per appointment varied, 

affected by factors such as the length of research participants’ 

appointments and the program support services sponsoring agencies had 

ORAU perform.

Page 7 GAO-16-128 Federal Research Opportunities 

Agency Expenditures 

for the ORISE 

Program Increased 

from 2010 through 

2014, with Stipends 

Making Up the 

Largest Portion of 

Expenses
During fiscal years 2010 through 2014, sponsoring agencies, which 

included 11 departments and other federal agencies, expended a total of 

$776.4 million for the ORISE program.

Page 8 GAO-16-128 Federal Research Opportunities 

11 DOD, HHS, and DOE collectively 

had the highest expenditures for the program (over 87 percent) over that period 

and had the highest number of appointments in fiscal year 2014 (over 88 

percent).12 Within DOD, the Army was the primary component that sponsored 

ORISE research participants, accounting for 77 percent of DOD expenditures 

over the 5-year period and 70 percent of appointments in fiscal year 2014. 

Within HHS over the same time periods, the Food and Drug 

Administration (FDA) and Centers for Disease Control and Prevention 

(CDC) accounted for about 59 percent and 32 percent of expenditures, 

respectively, and about 53 percent and 36 percent of appointments. See 

figure 1 below and appendix II for further information on agencies’ 

expenditures and numbers of appointments.

Figure 1: Agency Expenditures (Fiscal Years 2010-2014) and Appointments (Fiscal Year 2014) for the Oak Ridge Institute for 

Science and Education Research Participation Program

 

11The program expenditure amounts are in nominal dollars and have not been adjusted 

for inflation, except where noted. 

12Since appointments that cross fiscal years are counted once in each fiscal year, appointment 

numbers from different fiscal years could not be combined.

DOD, DOE, and HHS 

Expended the Most for the 

ORISE Program from 

2010 through 2014, as 

Overall Expenditures and 

Participation Increased
Note: Expenditures do not add up to $776.4 million due to rounding. Expenditures are in nominal 

dollars and have not been adjusted for inflation. We use the number of active appointments rather 

than the number of individual participants because participants can have multiple appointments. For 

example, in fiscal year 2014, 172 individuals had multiple appointments. In addition, since 

appointments that cross fiscal years are counted once in each fiscal year, appointment numbers from 

different fiscal years could not be combined. This figure does not include research participants 

categorized as ORAU employees or ORISE research participants in nonfederal entities. The number 

of appointments for fiscal year 2014 does not add up to 5,854 because it does not include one 

appointment that began in fiscal year 2014 and did not incur expenditures until fiscal year 2015.

Sponsoring agencies’ total annual expenditures increased from $112.3 

million in fiscal year 2010 to $193.8 million in fiscal year 2014, a 73 

percent increase (61 percent when adjusted for inflation), and the number 

of appointments grew from 4,128 to 5,854, a 42 percent increase (see fig. 

2 below and app. II for further information).

Page 9 GAO-16-128 Federal Research Opportunities 

13

Figure 2: Total Expenditures and Appointments for the Oak Ridge Institute for 

Science and Education Research Participation Program, Fiscal Years 2010-2014

Note: Total expenditures are in nominal dollars and have not been adjusted for inflation. We use the 

number of active appointments within each fiscal year rather than the number of individual 

participants because participants can have multiple appointments. For example, in fiscal year 2014, 

172 individuals had multiple appointments. This figure does not include research participants 

categorized as ORAU employees or ORISE research participants in nonfederal entities.

 

13The inflation adjustment calculation was based on the fiscal year chain-weighted gross domestic 

product price index. We use the number of active appointments within each fiscal year rather than 

the number of individual participants because participants can have multiple appointments. 

For example, in fiscal year 2014, 172 individuals had multiple appointments. In addition, 

since appointments that cross fiscal years are counted once in each fiscal year, 

appointment numbers from different fiscal years could not be combined.
An ORAU official who maintains data on appointments attributed the 

growth in the number of appointments to an increase in the program’s 

popularity, which led to the addition of new sponsoring agencies and 

increases in the number of appointments per sponsoring agency. Agency 

component officials we interviewed cited a variety of reasons for wanting 

to sponsor ORISE research participants, including:

· access to the ORISE program’s recruiters and network of connections 

at academic institutions,

· administrative support from the ORISE program that the sponsoring 

agencies could not easily supply themselves, and

· the speed, flexibility, and relatively low overhead cost of the ORISE 

program.

For example, an official who managed the research participation program 

at the U.S. Army Medical Research Institute of Infectious Diseases told us 

that the cost of hiring and managing staff to administer their own program 

would cost more than the overhead that they pay for the ORISE program.

The average total expenditure per appointment in the ORISE program 

also increased from fiscal year 2010 through fiscal year 2014, from about 

$27,200 per appointment in fiscal year 2010 to about $33,100 per 

appointment in fiscal year 2014.

Page 10 GAO-16-128 Federal Research Opportunities 

14 Expenditures per appointment may have 

risen for a variety of reasons, such as changes in the average education level 

of research participants and the average length of their appointments. For 

example, the proportions of appointments at different education levels in 

fiscal year 2014 shifted compared to the proportions in fiscal year 2010, 

with recent graduate and postdoctoral appointments increasing 65 

percent and 68 percent, respectively, while undergraduate appointments 

increased 12 percent. An ORAU official said that postgraduate 

appointments generally command higher stipends than undergraduate 

appointments. For example, according to information provided by FDA’s 

Center for Drug Evaluation and Research, monthly stipends at their 

center could be as high as $2,897 for currently enrolled undergraduate 

 

14ORAU does not track certain data about ORISE research participants, such as their full-time or 

part-time status, and appointments that cross fiscal years are counted once in each fiscal year. As a 

result, direct comparisons between agencies as to their relative expenses per appointment 

length could not be made.
students and as high as $7,569 for postgraduates with PhD degrees. The 

official said that postgraduate appointments at their center also last longer 

than undergraduate appointments, resulting in higher expenditures per 

appointment.

From fiscal year 2010 through fiscal year 2014, stipends—funds paid to 

research participants to defray their costs of living during their 

appointments—comprised the majority of agencies’ expenditures for the 

ORISE program. Sponsoring agencies’ other expenditures for the 

program included the following categories of expenses:

· Travel and other research participant expenses: Funds paid to 

research participants to cover particular expenses not covered by 

their stipends, such as expenses for travel to conferences or other 

appointment-related destinations.

· Program support and overhead: Funds paid to DOE to cover 

ORAU’s expenses for administering the appointment of research 

participants at agencies. These expenses included (1) program 

support expenses—direct expenses for services ORAU provides to 

agencies, such as managing recruitment activities, and (2) general 

and administrative expenses—indirect expenses such as building 

expenses, paid by agencies as a fixed percentage (negotiated by 

DOE and ORAU) of total expenditures on the ORISE program.

· Federal administrative and security charges: Fees paid to DOE by 

other sponsoring agencies, including (1) a federal administrative 

charge of 3 percent of an agency’s total expenditures on the ORISE 

program to offset DOE’s administrative expenses for work conducted 

on behalf of other agencies and (2) a charge applied to Strategic 

Partnership Projects to supplement DOE support for safeguards and 

security expenses.

Page 11 GAO-16-128 Federal Research Opportunities 

15

 

15Section 3137 of the Strom Thurmond National Defense Authorization Act for Fiscal Year 1999 

requires the Secretary of Energy to impose a federal administrative charge—not to exceed 3 

percent of the full cost incurred in carrying out the research and activities—on agencies for 

which research and other activities are conducted at DOE facilities. 42 U.S.C. § 

7259a(b)(2)(A). According to DOE officials, section 3137 requires DOE to impose a 

federal administrative charge on agencies with ORISE research participants. The 

safeguards and security fee is limited to an amount proportional to DOE direct funding for 

safeguards and security activities. 

Most Expenses Were for 

Stipends, and Several 

Factors Contributed to 

Variations in Agencies’ 

Expenditures per 

Appointment
Figure 3 shows the percentage of expenditures for each category of 

expense.

Figure 3: Agency Expenditures for the Oak Ridge Institute for Science and 

Page 12 GAO-16-128 Federal Research Opportunities 

Education (ORISE) Research Participation Program by Type of Expense, Fiscal 

Years 2010-2014

Note: Expenditures do not add up to $776.4 million due to rounding. Expenditures are in nominal 

dollars and have not been adjusted for inflation. This figure does not include research participants 

treated by the ORISE program as employees or ORISE research participants in nonfederal entities.

Sponsoring agencies’ expenditures per appointment in the ORISE 

program varied among agencies. In each year from fiscal year 2010 

through fiscal year 2014, the lowest average expenditure per appointment 

for a sponsoring agency was $14,396 or less, and the highest average 

expenditure per appointment was $42,996 or more. For example, in fiscal 

year 2014, the Department of the Interior expended an average of 

$12,246 per appointment, while the Environmental Protection Agency 

expended an average of $44,099 per appointment. The proportions 

expended for different categories of expenses also varied. For example, 

data provided by ORAU showed that the proportion agencies expended 

on stipends ranged from 69 percent to 88 percent in fiscal year 2014.

We identified the following factors that contributed to per-appointment 

expenditures varying among agencies:
· Research participants’ appointment terms. Differences in the 

terms that sponsoring agency components set for research 

participants’ appointments contributed to variation in expenditures per 

appointment. Some appointments lasted for days, weeks, or months, 

while others lasted for a full year or more. For example, FDA’s 

National Center for Toxicological Research’s Summer Student 

Research Program placed research participants in a 10-week summer 

program. In contrast, the National Library of Medicine’s Associate 

Fellowship Program placed research participants in 1- or 2-year 

residency programs. In addition, some appointments were full-time, 

while others were part-time.

· Methods of setting stipends. Officials at sponsoring agency

components reported that they used differing methods to set research 

participants’ stipends. ORAU officials said that they sometimes 

provided advice to the agencies, but that the agencies ultimately set 

their own stipends. Almost all of the officials we interviewed at 

sponsoring agency components said that they considered applicants’ 

education levels when setting stipends, but they varied in the other 

factors they considered. For example, some used the Office of 

Personnel Management’s General Schedule pay scale, but others did 

not. The officials also differed in the extent to which they considered 

other factors, including prior work experience, salaries in the private 

and government sectors, stipends received by research participants in 

other programs, and geographic location. Some of the officials said 

that they set fixed stipends for all research participants, but others 

said that they determined stipends individually or made exceptions to 

fixed stipends when attempting to fill particular appointments.

· Other expenses covered. Sponsoring agency components chose to 

reimburse their research participants for different types and amounts 

of expenses not covered by their stipends. For example, in fiscal year 

2014, the Air Force expended an average of $492 per appointment to 

pay for participants’ travel expenses, while the Environmental 

Protection Agency expended an average of $1,387 per appointment 

for that purpose.

Page 13 GAO-16-128 Federal Research Opportunities 

16 Other expenses that can vary among sponsoring agency 

components include payment of research participants’ tuition and fees at 

their academic institutions; reimbursement for the costs of moving to a 

 

16From fiscal year 2010 through fiscal year 2014, travel expenditures represented $23.1 

million, or 76 percent, of the $30.4 million agencies paid for participant expenses other 

than stipends. 
research site; allowances for housing at research sites; payment of 

visa processing fees for foreign research participants; and purchase 

of safety equipment, books, and research supplies.

Page 14 GAO-16-128 Federal Research Opportunities 

17

· Services performed by ORAU. Sponsoring agency components 

selected from and paid for many different services performed by 

ORAU. These services included managing recruitment activities, 

processing applications, making and monitoring appointments, 

designing and implementing program enhancements, paying stipends, 

administering other research participant expenses and insurance, 

managing domestic and foreign travel, analyzing and providing 

financial reports, developing and administering program goals and 

objectives, handling immigration status issues, and other tasks. 

Agencies’ selections of these services determined the amount that 

they paid in program support expenses for each of their appointments.

According to DOE officials, the ORISE program consists of a set of 

distinct activities, or separate programs, that ORAU carries out on behalf 

of DOE and other sponsoring agency components. As a result, DOE 

considers responsibility for assessing the effectiveness of ORISE 

program activities to be dispersed among the sponsoring agencies, each 

of which may have separate objectives for sponsoring research 

participants. Sponsoring agency components we reviewed use 

questionnaires and other methods to assess how well the program is 

working. Responsibility for ensuring research participants do not perform 

inherently governmental functions is also dispersed among sponsoring 

agencies. However, documents provided by DOE, DOD, and HHS 

components to research participants, coordinators, and mentors contain 

varying levels of detail on the prohibition on nonfederal employees 

performing inherently governmental functions. Without detailed guidance, 

sponsoring agencies have limited assurance that the prohibition is being 

followed.

 

17In addition, all research participants must either enroll in ORAU’s health insurance plan or 

provide proof of insurance through another carrier. ORAU officials responsible for 

expenditure data said that some sponsoring agency components reimbursed participants 

for the cost of health insurance by including this expense in the stipends they paid 

participants. 

Assessment of the 

ORISE Program and 

Guidance on 

Inherently 

Governmental 

Functions Varies 

Among Sponsoring 

Agency Components
In May 2013, the National Science and Technology Council, which 

coordinates executive branch science and technology policy, released its 

5-year strategic plan for STEM education, which stated that federal 

agencies would focus on building and using evidence-based approaches 

to evaluate the federal investment in STEM education. DOE officials told 

us that, because the ORISE program consists of separate activities that 

ORAU carries out on behalf of DOE and other sponsoring agencies, 

these agencies choose whether to assess the effectiveness of ORISE 

program activities as part of their other investments in STEM education. 

As a result, other than periodically evaluating ORAU’s performance (with 

input from sponsoring agencies) under its contract to determine ORAU’s 

award fee, DOE does not assess the overall effectiveness of the activities

that ORAU carries out under the ORISE program, according to a DOE 

official. For example, the official said DOE does not assess how ORISE 

program activities at other sponsoring agencies contribute to the ORISE 

program’s objective to enhance the quantity, quality, and diversity of the 

future scientific and engineering workforce and to increase the scientific 

and technical literacy of the U.S. citizenry.

Page 15 GAO-16-128 Federal Research Opportunities 

18

Sponsoring agency components establish their own objectives for 

sponsoring research participants and decide whether and how to assess 

the extent to which the ORISE program meets those objectives, 

according to DOE officials. Some but not all DOE, DOD, and HHS 

components have used questionnaires, and some components have used 

other methods to assess how well the ORISE program is working in the 

short term, such as over the course of a research participant’s 

appointment. In particular, some components use questionnaires 

developed with assistance from ORAU and administered to research 

participants, and sometimes to mentors. ORISE program coordinators 

and other officials at sponsoring agency components described other 

methods they use to assess the program, such as asking research 

participants about their experiences and monitoring the progress of 

research participants’ research projects, research participants’ 

publications and presentations related to their research, and the number 

of current agency employees who were past ORISE research 

participants. In addition, one of the program support functions that ORAU 

can offer to sponsoring agencies at the cost of the service is performing 

 

18The objective of the ORISE program is described in the statements of work that sponsoring 

agencies and DOE develop.

Sponsoring Agency 

Components Chose 

Whether and How to 

Assess the ORISE 

Program
an assessment of ORISE program effectiveness. In response to a request 

from the sponsoring agency component, ORAU performed such an 

assessment for the Joint Prisoner of War/Missing in Action Accounting 

Command and issued a report in August 2014.

Page 16 GAO-16-128 Federal Research Opportunities 

19

The methods being used by the sponsoring components we reviewed 

assess how well the program is meeting the short-term needs of research 

participants and mentors. For example, some research participant 

questionnaires included questions about research participants’ 

satisfaction with their assignment, training, mentoring, stipends, and 

program administration. DOD mentor questionnaires include questions on 

reasons for renewing a research participant’s appointment and research 

participants’ skills and knowledge.

A DOE Office of Science official told us that DOE is working with other 

agencies to develop methods for assessing the long-term outcomes of 

STEM education efforts, such as the ORISE program increasing the 

diversity of the STEM workforce. The official noted that, without such 

methods, they face challenges in assessing the long-term effectiveness of 

the ORISE program. For example, according to the official, such 

challenges include developing methods to track research participants 

over the course of their careers and determining the extent to which a 

participant’s degree of success in a STEM field is a result of the ORISE 

program as opposed to other educational experiences.

 

19Due to a merger of offices, the military’s Joint Prisoner of War/Missing in Action Accounting 

Command is now the Defense Prisoner of War/Missing in Action Accounting Agency. 
In 2011, OMB’s Office of Federal Procurement Policy issued guidance to 

assist agency officers and employees in ensuring that only federal 

employees perform work that is inherently governmental or otherwise 

needs to be reserved to the public sector.

Page 17 GAO-16-128 Federal Research Opportunities 

20 This guidance directs agencies to 

develop and maintain internal procedures; take appropriate steps to help 

employees understand and meet their responsibilities; and periodically evaluate 

the effectiveness of their internal management controls for reserving work for 

federal employees.21 In accordance with OMB’s guidance, agencies that 

sponsor ORISE research participants are responsible for ensuring that research 

participants at their agencies do not perform inherently governmental functions.

Documents we reviewed that are issued by DOE, DOD, and HHS, 

regarding research participants at their agencies, and that are used by 

sponsoring agency components’ coordinators, mentors, and research 

participants varied in level of detail on activities considered inherently 

governmental functions. For example, within HHS, ORISE program 

handbooks from FDA’s Center for Veterinary Medicine and Center of 

Drug Evaluation and Research included examples of activities research 

participants should not perform, such as serving as a drug, device, safety, 

or facilities reviewer.22 Similarly, within DOD, the research participant 

appointment letters used by the Office of the Under Secretary of Defense for 

Acquisition, Technology, and Logistics included detailed guidance, such as a 

statement that research participants should not accept policy, budget, or 

program management authority. In contrast, sample appointment letters 

that we reviewed used by HHS’s CDC and DOD’s U.S. Army 

Environmental Command stated only that the research participant will not 

enter into an employee/employer relationship with ORISE, DOE, or any 

 

2076 Fed. Reg. 56227, 56236 (Sept. 12, 2011). OMB’s guidance includes examples of inherently 

governmental functions such as direction and control of federal employees, determination of 

agency policy, drafting congressional testimony, and determining budget policy, guidance, 

and strategy. The guidance also includes examples of functions that are generally not 

considered to be inherently governmental but are closely associated with the performance 

of inherently governmental functions, such as providing support for developing policies by 

drafting documents and conducting analysis, feasibility studies, and strategy options. 

2176 Fed. Reg. 56227, 56240 (Sept. 12, 2011). 

22As part of a standard set of questions, we asked DOE, DOD, and HHS officials we 

interviewed for written guidance, such as policy manuals, that describe procedures for 

ensuring that research participants’ projects do not include activities that are reserved for 

federal government employees. HHS officials provided handbooks from FDA’s Center for 

Veterinary Medicine and Center for Drug Evaluation and Research as examples of 

guidance. 

Documents Used by DOE, 

DOD, and HHS for 

Research Participants and 

Mentors Provide Varying 

Levels of Detail on 

Inherently Governmental 

Functions
other office or agency, and did not specifically cite the inherently 

governmental activities prohibition. The terms of appointment developed 

by ORAU and used by DOE, DOD, and HHS to make research participant 

appointments states only that the appointment is an educational 

experience and not a contract of employment.

Page 18 GAO-16-128 Federal Research Opportunities 

23

Statements of work agreed upon as part of interagency agreements 

between DOE and sponsoring agencies also varied in their level of detail 

about activities considered to be inherently governmental functions. For 

example, a statement of work for the CDC stated that ORISE research 

participation projects should not include activities reserved for federal 

employees, such as those involving budget or program management 

authority. In contrast, a statement of work for the National Institutes of 

Health did not include this level of detail, stating only that individuals 

selected for appointments do not become employees.

DOE and other sponsoring agency officials noted that ORISE research 

participants are assigned to research projects that generally do not 

involve inherently governmental functions. A DOE Office of Science 

official said that the research focus of most ORISE appointments reduced 

the risk of those research participants performing inherently governmental 

functions. However, GAO found that some research participants’ projects 

involve activities that are closely associated with inherently governmental 

functions, such as participating in policy and strategic planning meetings, 

which may increase the risk of the participants performing inherently 

governmental functions.24 The DOE Office of Science official described how, 

in such cases, DOE provided more detailed briefings on inherently 

governmental functions for certain research participants, as well as 

briefings for their mentors. However, officials at other sponsoring agency 

components we interviewed did not describe providing such briefings as a 

 

23The terms of appointment is a document to be signed by ORISE research participants, by which 

they agree to be bound by the terms described in the document, such as requirements 

related to travel; limitations on access to classified and proprietary information; and 

safeguarding of property or equipment issued to research participants.

24By participating in certain policy and strategic planning meetings, ORISE research participants 

may have an opportunity to provide support for developing policies, which is a function generally 

not considered to be inherently governmental but rather one that is closely associated with the 

performance of inherently governmental functions. Under OMB’s guidance, when such 

closely associated functions are performed by non-federal employees, agencies should 

provide greater attention and an enhanced degree of management overnight of their 

activities.
standard practice for coordinators, mentors, or research participants. For 

example, the position description for a research participant in the DOD 

Office of the Under Secretary of Defense for Acquisition, Technology, and 

Logistics included participating in policy and strategic planning meetings, 

but officials at this DOD component did not describe providing briefings 

on inherently governmental functions, increasing the importance of written 

guidance.

Not having detailed guidance increases the risk that coordinators 

responsible for managing overall participation in the program and mentors 

responsible for directing research participants’ day-to-day activities may 

overlook the possibility of research participants engaging in inherently 

governmental functions, especially in cases where participants’ activities 

are closely associated with inherently governmental functions. 

Development of detailed guidance could help sponsoring agencies fulfill 

their responsibilities as identified in OMB’s Office of Federal Procurement 

Policy guidance on inherently governmental functions.

By providing hands-on research experiences in government agencies for 

students, postgraduates, and faculty, the ORISE research participation 

program makes an important contribution to federal efforts to help 

prepare students and teachers for careers in STEM fields. Responsibility 

for administering the program is dispersed among agencies that sponsor 

research participants. In particular, agencies are responsible for ensuring 

that research participants do not perform inherently governmental 

functions—for example, by developing guidance and other documents for 

research participants, coordinators, and mentors. Having this 

responsibility allows agencies to tailor guidance on inherently 

governmental functions to the features of the ORISE program at their 

agencies, such as the types of projects to which research participants are 

assigned. However, the level of detail in documents currently used by 

DOE, DOD, and HHS varies, with some documents describing specific 

types of activities that are inherently governmental functions and others 

only providing general statements that research participants are not 

federal government employees. More detailed guidance can help ORISE 

coordinators, mentors, and research participants ensure that they are 

adhering to the prohibition on research participants as nonfederal 

government employees performing inherently government functions.

Page 19 GAO-16-128 Federal Research Opportunities 

Conclusions
We recommend that the Secretaries of Energy, Defense, and Health and 

Human Services develop detailed guidance to ensure that ORISE 

program coordinators, mentors, and research participants are fully 

informed of the prohibition on nonfederal employees performing 

inherently governmental functions.

We provided a draft of this report to DOE, DOD, and HHS for their review 

and comment. In their written comments, reproduced in appendices III

through V, DOE, DOD and HHS concurred with our recommendation. 

DOE and HHS also provided technical comments, which we incorporated 

as appropriate.

In their written comments, DOE, DOD, and HHS described the measures 

they will take to implement our recommendation on inherently 

governmental functions. In particular, DOE stated that it plans to provide 

detailed guidance to all relevant parties involved in DOE-sponsored 

research participation activities administered through ORISE within 180 

days, following consultation with relevant DOE offices. DOD stated 

detailed guidance will be developed to further ensure those connected 

with the ORISE program are fully informed of the prohibition on nonfederal employees performing inherently governmental functions. HHS 

stated that they are developing an agency-wide policy, including a section 

on inherently governmental functions that will provide guidance to agency 

program coordinators, mentors, and research participants.

In its letter and technical comments, DOE stated that the draft report did 

not reflect detailed discussions we had with DOE officials regarding 

inherently governmental functions. In addition, DOE stated that the draft 

report significantly understated the extent to which DOE communicates 

the prohibition of inherently governmental functions to sponsored 

participants and agency mentors. We do not believe our report 

understates DOE’s efforts. For example, our report includes a discussion 

of the detailed briefings that DOE Office of Science officials provide on 

inherently governmental functions to research participants selected for a 

program designed to expose the participants to federal policymaking. 

Other DOE, DOD, and HHS sponsoring agency components we 

interviewed did not describe a similar practice for their coordinators, 

mentors, or research participants. Our report’s discussion of these 

briefings, as well as of documents issued by DOE for the ORISE 

program, reflect the extent of communications on inherently governmental 

functions that DOE provided to us.

Page 20 GAO-16-128 Federal Research Opportunities 

Recommendation for 

Executive Action

Agency Comments 

and Our Evaluation
We are sending copies of this report to the appropriate congressional 

committees; the Secretaries of Energy, Defense, and Health and Human 

Services; and other interested parties. In addition, the report is available 

at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, 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 report. GAO staff who made key contributions to 

this report are listed in appendix VI.

Sincerely yours,

John Neumann

 Director, Natural Resources and Environment

Page 21 GAO-16-128 Federal Research Opportunities 
Appendix I: Examples of Subject Areas for 

ORISE Research Participant Projects in Fiscal 

Year 2014

Page 22 GAO-16-128 Federal Research Opportunities 

Sponsoring agency Examples of subject areas

Department of Agriculture Improving prevention and treatments of emerging foreign animal diseases, climate change impacts on 

forests, porcine epidemic diarrhea virus, and sensor networks on variable rate irrigation systems.

Department of Defense Examples of subject areas

Air Force Laser systems, nanomaterials, acoustics, neurobiology, additive manufacturing, civil engineering, 

cognitive modeling, intelligent sensors, exercise science, and visual analytics.

Army Weather impacts on military projects, cognitive function and psychological performance of soldiers, 

health promotion and wellness, environmental medicine, improving military field equipment, and science 

and technology policy.

Navy Infectious disease or deployment health surveillance, clinical and health care epidemiology, optical 

coherence tomography, and aeromedical studies.

OtheraForensic sciences, human immunodeficiency virus/acquired immune deficiency syndrome prevention, 

public health and preventive medicine studies, and science and technology policy.

Department of Energy Neutron scattering, fusion energy, efficiency of renewable energy sources, computational sciences, 

materials sciences, process controls of advanced power systems, gas sensors and high temperatures, 

improving extraction of earth elements, quantum computing, biofilms and biotechnology, advanced 

manufacturing (carbon fiber), climate change, and science and technology policy.

Department of Health and 

Human Services

Examples of subject areas

Centers for Disease 

Control and Prevention

Infectious diseases (e.g., influenza, sexually transmitted, food borne, vector borne, respiratory), chronic 

diseases (e.g., heart, obesity, cancer), environmental health, toxic substances, health statistics, and 

public health preparedness.

Food and Drug 

Administration

Toxicology, food safety, drug evaluation and testing, biological therapeutics, tobacco products, blood 

products, medical devices, biotechnology products, translational sciences, women’s health, vaccines, 

cell and gene therapies, and regulatory science.

National Institutes of 

Health

Localization of proteins using molecular markers, gene regulatory effects in cancer, medical informatics, 

and central nervous system injuries.

OtherbPublic health economics, population based model testing, clinical care models, minority health, women’s 

health, tobacco prevention initiatives, national human immunodeficiency virus/acquired immune 

deficiency syndrome strategies, and geospatial analysis of underserved populations.

Department of Homeland 

Security

Encryption for criminal databases, improving materials for coastal bridges, computer simulations of 

potential terrorist attacks or natural disasters, brain-like modeling systems, searchable databases of 

potential threats, human trafficking, and detecting and identifying explosive-related threats.

Department of Housing and 

Urban Development

Data analysis of housing and urban development impacts and value on communities.

Department of the Interior Data collection and surveys related to conservation measures for fish and wildlife.

Department of State Clean energy and climate change policy and analyses in the international economy, and building 

efficiencies.

Environmental Protection 

Agency

Climate change, software codes for aerial sampling systems, urban ecosystems, nanoparticles and 

surface coating, waste disposal, safety of water supply, and biomarkers for environmental contaminants.

Federal Bureau of 

Investigation

Juvenile prostitution and child abduction, causes of postmortem hair root banding, forensic applications 

of isotopes, crimes against adults, and identification of facial phenotypic markers.

Source: Oak Ridge Associated Universities. | GAO-16-128.

a

Includes Office of the Secretary, Office of Diversity Management and Equal Opportunity, National 

Geospatial-Intelligence Agency, Defense Threat Reduction Agency, Defense Prisoner of War/Missing 

in Action Accounting Command, and U.S. Southern Command.

b

Includes Office of the Secretary and Health Resources and Services Administration, and Center for 

Medicare and Medicaid Innovation.

Appendix I: Examples of Subject Areas for 

ORISE Research Participant Projects in 

Fiscal Year 2014
Appendix II: Federal Expenditures for and 

Appointments in the ORISE Research 

Participation Program

The following tables detail federal agencies’ expenditures for and 

research participant appointments they sponsored as part of the Oak 

Ridge Institute for Science and Education (ORISE) research participation 

program for fiscal years 2010 through 2014. Table 1 identifies agencies’ 

total annual expenditures for their involvement in the ORISE program. 

Table 2 identifies the numbers of appointments at each agency for each 

year. Table 3 details each agency’s total expenditures for the ORISE 

program for fiscal years 2010 through 2014 by type of expense, including 

stipends, travel, other research participant expenses, program support 

and overhead, and federal administrative and security charges. In each 

table, the three agencies that account for the largest share of 

expenditures and appointments—the Department of Health and Human 

Services (HHS), the Department of Defense (DOD), and the Department 

of Energy (DOE)—are broken out into component agencies that 

sponsored research participants.

Table 1: Federal Agency Expenditures for the Oak Ridge Institute for Science and Education (ORISE) Research Participation 

Page 23 GAO-16-128 Federal Research Opportunities 

Program, Fiscal Years 2010-2014

Expenditures are in thousands of dollars and have not been adjusted for inflation.

Category FY 2010 FY 2011 FY 2012 FY 2013 FY 2014 Total 

Department of Health and Human 

Services (HHS)

Food and Drug 

Administration

$31,185 $42,388 $46,779 $44,502 $45,290 $210,144

Centers for Disease Control 

and Prevention

17,636 17,844 22,034 26,246 28,479 112,239

National Institutes of Health 4,612 4,272 4,089 3,535 3,618 20,126

Center for Medicare and 

Medicaid

Innovation

- - 1,588 3 735 2,326

Other HHS 712 1,108 1,216 2,897 3,591 9,524

HHS total 54,145 65,612 75,706 77,183 81,713 354,359

Department of Defense (DOD) Army 25,743 32,259 36,229 39,464 51,070 184,765

Air Force 1,654 2,251 5,656 6,180 6,989 22,730

Navy 1,383 1,954 2,080 1,513 1,237 8,167

Other DOD 2,018 3,098 5,340 5,837 6,728 23,021

DOD total 30,798 39,562 49,305 52,994 66,024 238,683

Department of Energy (DOE) DOE Headquarters 4,088 4,352 8,525 10,496 11,055 38,516

Oak Ridge National 

Laboratory

6,118 5,774 4,880 5,193 5,624 27,589

Other DOE laboratories/field 4,631 4,491 3,708 3,754 4,621 21,205

DOE total 14,837 14,617 17,113 19,443 21,300 87,310

Appendix II: Federal Expenditures for and 

Appointments in the ORISE Research 

Participation Program
Appendix II: Federal Expenditures for and 

Appointments in the ORISE Research 

Participation Program

Page 24 GAO-16-128 Federal Research Opportunities 

Other agencies Environmental Protection 

Agency

7,590 11,284 14,593 16,603 19,095 69,165

Department of Homeland 

Security

1,886 1,862 2,131 2,483 2,084 10,446

Federal Bureau of 

Investigation

1,350 1,351 1,723 1,297 1,267 6,988

Department of Agriculture 1,032 959 1,217 1,271 2,014 6,493

Nuclear Regulatory 

Commission

698 344 662 59 - 1,763

Department of the Interiora- 275 494 125 122 1,016

Department of State - - - - 221 221

Other agency total 12,556 16,075 20,820 21,838 24,803 96,092

Total for all agencies Not applicable $112,336 $135,866 $162,944 $171,458 $193,840 $776,444

Legend: FY = Fiscal Year.

Source: GAO analysis of Oak Ridge Associated Universities data. | GAO-16-128.

Note: Expenditures have been rounded to the nearest thousand dollars. Totals and subtotals 

represent the sums of these rounded numbers.

a

Includes the U.S. Geological Survey, which had ORISE research participants for fiscal years 2011 

through 2013.

Table 2: Federal Appointments in the Oak Ridge Institute for Science and Education (ORISE) Research Participation Program 

by Agency, Fiscal Years 2010-2014

Category FY 2010 FY 2011 FY 2012 FY 2013 FY 2014 

Department of Health and 

Human Services (HHS)

Food and Drug Administration 840 1,009 1,113 1,123 1,131

Centers for Disease Control and 

Prevention

555 518 572 669 762

National Institutes of Health 161 162 146 142 135

Center for Medicare and Medicaid 

Innovation

- - 73 71 22

Other HHS 33 37 29 53 82

HHS total 1,589 1,726 1,933 2,058 2,132

Department of Defense (DOD) Army 740 901 979 1,070 1,336

Air Force 77 117 212 258 378

Navy 46 53 56 43 34

Other DOD 54 88 167 122 165

DOD total 917 1,159 1,414 1,493 1,913

Department of Energy (DOE) DOE Headquarters 285 242 281 333 411

Oak Ridge National Laboratory 695 588 531 557 591

Other DOE laboratories/field 200 175 152 137 156

DOE total 1,180 1,005 964 1,027 1,158

Other agencies Environmental Protection Agency 243 288 325 369 433
Appendix II: Federal Expenditures for and 

Appointments in the ORISE Research 

Participation Program

Page 25 GAO-16-128 Federal Research Opportunities 

Category FY 2010 FY 2011 FY 2012 FY 2013 FY 2014 

Department of Homeland Security 100 83 109 123 125

Department of Agriculture 24 25 28 29 52

Federal Bureau of Investigation 37 40 39 29 30

Department of the Interiora- 4 4 1 10

Department of Housing and Urban 

Development

- - - - 1

b

Department of State - - - - -

c

Nuclear Regulatory Commission 38 35 46 - -

Other agency total 442 475 551 551 651

Total for all agencies Not applicable 4,128 4,365 4,862 5,129 5,854

Legend: FY = Fiscal Year.

Source: GAO analysis of Oak Ridge Associated Universities data. | GAO-16-128.

Note: We use the number of active appointments within each fiscal year rather than the number of 

individual participants because participants can have multiple appointments. For example, in fiscal 

year 2014, 172 individuals had multiple appointments. In addition, since appointments that cross 

fiscal years are counted once in each fiscal year, appointment numbers from different fiscal years 

could not be combined.

a

Includes the U.S. Geological Survey, which had ORISE research participants from 2011 through 

2013.

b

The Department of Housing and Urban Development had one research participant whose 

appointment began in September 2014, but ORISE did not report expenditures for that research 

participant until fiscal year 2015.

c

In fiscal year 2014, the Department of State partially funded a research participant in a DOE 

program.

Table 3: Federal Agency Total Expenditures for the Oak Ridge Institute for Science and Education (ORISE) Research 

Participation Program by Type of Expense, Fiscal Years 2010-2014

Expenditures are in thousands of dollars and have not been adjusted for inflation.

Category Stipends Research 

participant 

travel

Other 

research 

participant 

expenses

a

Overhead 

and 

program 

supportb

Federal 

administra

tive 

charge 

and 

securityc

Total 

Department of Health and 

Human Services (HHS)

Food and Drug

Administration

$181,410 $3,226 $1,140 $17,854 $6,514 $210,1

44

Centers for Disease 

Control

and Prevention

94,145 3,989 658 9,977 3,471 112,24

0

National Institutes of 

Health

15,683 1,022 365 2,427 628 20,125
Appendix II: Federal Expenditures for and 

Appointments in the ORISE Research 

Participation Program

Page 26 GAO-16-128 Federal Research Opportunities 

Center for Medicare 

and

Medicaid Innovation

1,939 32 - 283 72 2,326

Other HHS 8,259 126 25 819 295 9,524

HHS total 301,436 8,395 2,188 31,360 10,980 354,35

9

Department of Defense 

(DOD)

Army 151,246 5,338 1,983 20,562 5,637 184,76

6 

Air Force 18,093 652 879 2,417 690 22,731

Navy 6,576 357 51 928 255 8,167

Other DOD 17,161 1,402 332 3,475 650 23,020

DOD total 193,076 7,749 3,245 27,382 7,232 238,68

4

Department of Energy (DOE) DOE Headquarters 27,596 2,083 686 8,151 - 38,516

Oak Ridge National

Laboratory

21,745 934 166 4,744 - 27,589

Other DOE

laboratories/field

16,917 610 664 3,012 - 21,203

DOE total 66,258 3,627 1,516 15,907 - 87,308

Other agencies Environmental 

Protection

Agency

58,539 2,158 134 6,190 2,145 69,166

Department of 

Homeland

Security

7,747 637 47 1,988 27 10,446

Federal Bureau of

Investigation

5,842 256 39 634 216 6,987

Department of 

Agriculture

5,339 154 50 893 58 6,494

Nuclear Regulatory

Commission

827 88 112 680 57 1,764

Department of the 

Interiord

708 47 3 227 32 1,017

Department of State 192 - 2 20 7 221

Other agency total 79,194 3,340 387 10,632 2,542 96,095

Total for all agencies Not applicable $639,964 $23,111 $7,336 $85,281 $20,754 $776,4

46

Source: GAO analysis of Oak Ridge Associated Universities data. | GAO-16-128.

Note: Expenditures have been rounded to the nearest thousand dollars. Totals and subtotals 

represent the sums of these rounded numbers.

a

Include specific research participant expenses such as tuition and fee payments, relocation 

expenses, housing allowances, visa processing fees, and other expenses.
Appendix II: Federal Expenditures for and 

Appointments in the ORISE Research 

Participation Program

b

Includes both general and administrative overhead, which consists of indirect expenses ORISE 

incurs during its operations, such as building expenses, and program support, which consists of 

ORISE’s charges to agencies for the services it provides, such as managing recruitment activities.

c

Includes fees agencies paid to DOE, including (1) a federal administrative charge of 3 percent of 

agencies’ total expenditures on the ORISE research participation program to offset DOE’s 

administrative expenses for work conducted on behalf of other agencies and (2) a safeguards and 

security charge to supplement DOE direct support for safeguards and security expenses.

d

Includes the U.S. Geological Survey, which had ORISE research participants from 2011 through 

2013.

Page 27 GAO-16-128 Federal Research Opportunities 
Appendix III: Comments from the Department 

of Energy

Page 28 GAO-16-128 Federal Research Opportunities 

Appendix III: Comments from the 

Department of Energy
Appendix III: Comments from the Department 

of Energy

Page 29 GAO-16-128 Federal Research Opportunities 
Appendix IV: Comments from the Department 

of Defense

Page 30 GAO-16-128 Federal Research Opportunities 

Appendix IV: Comments from the

Department of Defense
Appendix IV: Comments from the Department 

of Defense

Page 31 GAO-16-128 Federal Research Opportunities 
Appendix V: Comments from the Department 

of Health and Human Services

Page 32 GAO-16-128 Federal Research Opportunities 

Appendix V: Comments from the Department

of Health and Human Services
Appendix V: Comments from the Department 

of Health and Human Services

Page 33 GAO-16-128 Federal Research Opportunities 
Appendix VI: GAO Contact and Staff 

Acknowledgments

John Neumann, (202) 512-3841 or neumannj@gao.gov

In addition to the individual named above, Joseph Cook (Assistant 

Director), Sherri Doughty, Ellen Fried, Tobias Gillett, Kirsten Lauber, 

Gerald Leverich, Cynthia C. Norris, Stephanie Shipman, Kathryn Smith, 

Jeanette Soares, Sara Sullivan, and Thema Willette made key 

contributions to this report.

Page 34 GAO-16-128 Federal Research Opportunities 

Appendix VI: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Appendix VII: Accessible Data

Page 35 GAO-16-128 Federal Research Opportunities 

Department of Energy

Office of Science

Washington, DC 20585

December 21, 2015

Mr. John Neumann

Director, Natural Resources and Environment

Government Accountability Office

441 G Street

Washington, DC 20548 

Dear Mr. Neumann,

Thank you for the opportunity to comment on the draft Government 

Accountability Office (GAO) report entitled, "Federal Research 

Opportunities: DOE, DOD, and HHS Need Better Guidance for Participant 

Activities," (GA0-16-128). I am pleased to provide a response on •behalf 

of Department of Energy (DOE).

We believe the GAO did a commendable job of reviewing the science, 

technology, engineering, and mathematics (STEM) research participation 

activities carried out at the Oak Ridge Institute for Science and Education 

(ORISE), which is managed by the Oak Ridge Associated Universities 

under contract with DOE. The draft report provides an accurate and 

balanced view of the expenditures for the ORISE research participation 

activities by all sponsoring agencies and the information provided by DOE 

Appendix VII: Accessible Data

(361602)

Agency Comment 

Letter

Text of Appendix III: 

Comments from the 

Department of Energy

Page 1
Appendix VII: Accessible Data

to the GAO on DOE's assessment of the effectiveness of the ORISE 

activities.

Regarding the GAO Recommendation for Executive Action: ''We 

recommend that the Secretaries of Energy, Defense, and Health and 

Human Services, develop detailed guidance to ensure that ORISE 

program coordinators, mentors, and research participants are fully 

informed of the prohibition on the non-federal employees performing 

inherently governmental functions."

We agree. While the draft report does not reflect the detailed discussions 

between the GAO and DOE officials regarding inherently governmental 

functions and substantial documentation and guidance already provided 

by DOE (including the attached Acquisition Letter, AL-2015-07, issued in 

July 2015), the Department will take additional measures to provide 

detailed guidance to all relevant parties involved in DOE-sponsored 

research participation activities administered through ORISE. We 

anticipate that such measures will be determined within 180 days, 

following consultation with relevant DOE offices.

Thank you for the opportunity to provide comments on this draft report. 

Specific technical comments from the Department are provided in the 

attachment. If you have any questions or concerns, please call me at 

(202) 586-5430.

Sincerely,

Patricia M. Dehmer

Deputy Director for Science Programs

Office of Science

Attachments

Page 36 GAO-16-128 Federal Research Opportunities 

OFFICE OF THE UNDER SECRETARY OF DEFENSE

3150 DEFENSE PENTAGON

Page 2

Text of Appendix IV: 

Comments from the 

Department of Defense

Page 1
Appendix VII: Accessible Data

WASHINGTON, DC 20301-3150

ACQUISITION, TECHNOLOGY AND LOGISTICS

DEC 18 2015

Mr. John Neumann

Director, Natural Resources and Environment

U.S. Government Accountability Office

441 G Street, NW

Washington DC 20548

Dear Mr. Neumann:

Enclosed is the Department of Defense (DoD)'s proposed response to the 

GAO Draft Report, GA0-16-128, "FEDERAL RESEARCH OPPORTUNITI 

ES: DOE, DOD, and HHS Need Better Guidance for Pa1ticipant 

Activities," dated November 20, 2015 (GAO Code 361602). My point of 

contact for this matter is Harlan Knipes, who can be reached at 

harlan.r.knipes.civ@mail.mil.

Sincerely,

Judy Dahlgren

Director for Administration

Enclosure: As stated

GAO DRAFT REPORT DATED NOVEMBER 20, 2015 GAO-16-128 

(GAO CODE 361602)

“FEDERAL RESEARCH OPPORTUNITIES: DOE, DOD, AND HHS 

NEED BETTER GUIDANCE FOR PARTICIPANT ACTIVITIES”

DEPARTMENT OF DEFENSE RESPONSE TO THE GAO 

RECOMMENDATION

Page 37 GAO-16-128 Federal Research Opportunities 

Page 2
Appendix VII: Accessible Data

RECOMMENDATION 1: The GAO recommends that the Secretary of 

Defense develop detailed guidance to ensure that ORISE program 

coordinators, mentors, and research participants are fully informed of the 

prohibition on non-federal employees performing inherently governmental 

functions.

DoD RESPONSE: Concur with the GAO recommendation. Detailed 

guidance will be developed to further ensure those connected with the 

Oak Ridge Institute for Science and Education program are fully informed 

of the prohibition on non-federal employees performing inherently 

governmental functions.

Page 38 GAO-16-128 Federal Research Opportunities 

DEPARTMENT OF HEALTH & HUMAN SERVICES

OFFICE OF THE SECRETARY

Assistant Secretary for Legislation 

Washington, DC 20201

DEC 17 2015

James C. Cosgrove 

Director, Health Care

U.S. Government Accountability Office

441 G Street NW

Washington, DC 20548 

Dear Mr. Cosgrove:

Attached are comments on the U.S. Government Accountability Office's 

(GAO) report entitled, "Oversight and costs of the Oak Ridge Institute for 

Science and Education fellowship program " (GA0-16-128).

Text of Appendix V: 

Comments from the 

Department of Health and 

Human Services

Page 1
Appendix VII: Accessible Data

The Department appreciates the opportunity to review this report prior to 

publication.

Sincerely,

Jim R. Esquea

Assistant Secretary for Legislation

Attachment

GENERAL COMMENTS OF THE FOOD AND DRUG ADMINISTRA TION 

ON THE GOVERNMENT ACCOUNT ABILITY OFFICE'S DRAFT 

REPORT ENTITLED: FEDERAL RESEARCH OPPORTUNITIES - DOE, 

DOD, AND HHS NEED BETTER GUIDANCE FOR PARTICIPANT 

ACTIVITIES (GA0-16-128)

The HHS appreciates the opportunity to review and comment on this draft 

report.

GAO Recommendation

The Government Accountability Office (GAO) recommends that the 

Secretaries of Energy, Defense, and Health and Human Services develop 

detailed guidance to ensure that ORISE program coordinators, mentors, 

and research participants are fully informed of the prohibition on nonfederal employees performing inherently governmental functions.

FDA Response

HHS concurs with GAO's recommendation, and is currently developing an 

agency-wide policy, including a section on inherently governmental 

functions, that will provide such guidance to agency program 

coordinators, mentors, and research participants.

Data Table for Figure 1: Agency Expenditures (Fiscal Years 2010-2014) and 

Page 39 GAO-16-128 Federal Research Opportunities 

Appointments (Fiscal Year 2014) for the Oak Ridge Institute for Science and 

Education Research Participation Program

Expenditures by Agency, Fiscal Years 2010-2014

Page 2

Data Tables
Appendix VII: Accessible Data

Page 40 GAO-16-128 Federal Research Opportunities 

Agency Spending

Percent of Total 

Spending

Department of Health and Human 

Services

354,359,361.64 45.64

Department of Defense 238,683,098.53 30.74

Department of Energy 87,309,316.58 11.24

Other federal agencies 96,094,235.23 12.38

Appointments by Agency, Fiscal Year 2014

Agency Appointments

Percent of Total 

Appointments

Department of Health and Human 

Services

2,132 36.42

Department of Defense 1,913 32.68

Department of Energy 1,158 19.78

Other federal agencies 650 11.10

Source: Oak Ridge Associated Universities. | GAO-16-128

Data Table for Figure 2: Total Expenditures and Appointments for the Oak Ridge 

Institute for Science and Education Research Participation Program, Fiscal Years 

2010-2014

Fiscal Year Amount of expenditures

2010 112,335,628.49

2011 135,866,881.57

2012 162,943,243.51

2013 171,459,611.16

2014 193,840,647.25

Fiscal Year Number of appointments

2010 4,128

2011 4,365

2012 4,862

2013 5,129

2014 5,854

Source: Oak Ridge Associated Universities. | GAO-16-128
Appendix VII: Accessible Data

Data Table for Figure 3: Agency Expenditures for the Oak Ridge Institute for 

Page 41 GAO-16-128 Federal Research Opportunities 

Science and Education (ORISE) Research Participation Program by Type of 

Expense, Fiscal Years 2010-2014

2010-2014 Spending by Type

Type of Spending Amount of 

expenditures 

Percent of Total 

Spending

Stipends 639,966,119.12 82.42

Research participant travel 23,111,623.17 2.98

Other research participant expenses 7,335,907.41 0.94

Program support and overhead 85,280,657.98 10.98

Federal administrative charge and 

security

20,751,704.30 2.67

Source: Oak Ridge Associated Universities. | GAO-16-128
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