REDUCING FEDERAL

ADMINISTRATIVE AND

REGULATORY BURDENS ON

RESEARCH

A Report by the

RESEARCH BUSINESS MODELS WORKING GROUP

COMMITTEE ON SCIENCE

of the 

NATIONAL SCIENCE & TECHNOLOGY COUNCIL 

MAY 2018 
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About the National Science and Technology Council

The National Science and Technology Council (NSTC) is the principal means by which the Executive 

Branch coordinates science and technology policy across the diverse entities that make up the Federal 

research and development enterprise. A primary objective of the NSTC is to ensure science and 

technology policy decisions and programs are consistent with the President's stated goals. The NSTC 

prepares research and development strategies that are coordinated across Federal agencies aimed at 

accomplishing multiple national goals. The work of the NSTC is organized under committees that 

oversee subcommittees and working groups focused on different aspects of science and technology. 

More information is available at http://www.whitehouse.gov/ostp/nstc.

About the Office of Science and Technology Policy

The Office of Science and Technology Policy (OSTP) was established by the National Science and 

Technology Policy, Organization, and Priorities Act of 1976 to provide the President and others within 

the Executive Office of the President with advice on the scientific, engineering, and technological 

aspects of the economy, national security, homeland security, health, foreign relations, the 

environment, and the technological recovery and use of resources, among other topics. OSTP leads 

interagency science and technology policy coordination efforts, assists the Office of Management and 

Budget with an annual review and analysis of Federal research and development in budgets, and serves 

as a source of scientific and technological analysis and judgment for the President with respect to major 

policies, plans, and programs of the Federal Government. More information is available at 

http://www.whitehouse.gov/ostp.

About the Research Business Models Working Group

The purpose of the Research Business Models Working Group is to advise and assist the Committee on

Science and the NSTC on policies, procedures, and plans relating to business models for the 

performance and management of federally sponsored scientific research. The goal of the RBM is to 

solve problems. The subcommittee aims to facilitate a strong, coordinated, trans-agency effort to 

address important policy implications arising from the changing nature of basic and applied research, 

examine the influence of these changes on the business models for how the research is conducted, and 

review the challenges to improved performance and mechanisms for more transparent accountability 

of the research enterprise.

About this Document

Title II, Section 201 of the 2017 American Innovation and Competitiveness Act (AICA) directed the Office 

of Management and Budget (OMB), in coordination with the Office of Science and Technology Policy 

(OSTP), to establish an interagency working group (Working Group) to reduce administrative burdens 

on federally funded researchers while protecting the public interest through the transparency of and 

accountability for federally funded activities. The Act instructs the Working Group to review the 

relevant regulations and recommend ways to minimize the burden associated with the regulations, to 

address several specific, promising approaches to reducing burden, and to report to Congress annually 

for three years. 

OMB and OSTP agreed to convene the RBM to execute the Working Group responsibilities called out in 

the AICA. This report is the product of the RBM and is the first of the three mandated reports. 
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Copyright Information

This document is a work of the United States Government and is in the public domain (see 17 U.S.C. 

§105). Subject to the stipulations below, it may be distributed and copied with acknowledgment to 

OSTP. Copyrights to graphics included in this document are reserved by the original copyright holders 

or their assignees and are used here under the government’s license and by permission. Requests to 

use any images must be made to the provider identified in the image credits or to OSTP if no provider 

is identified. Printed in the United States of America, 2018.
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NATIONAL SCIENCE & TECHNOLOGY COUNCIL

Acting Chair

Ted Wackler, Deputy Chief of Staff and 

Assistant Director, OSTP

Staff

Chloe Kontos, Executive Director, NSTC

COMMITTEE ON SCIENCE

Co-Chairs

Francis Collins, Director, NIH

France Córdova, Director, NSF

Michael Kratsios, Deputy Assistant to the 

President, OSTP

Staff

Lloyd Whitman, OSTP Liaison and Assistant 

Director, OSTP

Sara Mazur, Executive Secretary, EPA

RESEARCH BUSINESS MODELS WORKING GROUP 

Co-Chairs

Michael Lauer, NIH

Teresa Grancorvitz, NSF

Executive Secretary

Cheryl Kitt, NIH/OD

Members

Jack Meszaros, OSTP

Chloe Kontos, OSTP

Sara Brenner, OSTP

Gil Tran, OMB

Emily Mok, OMB

Mariam Elsayed, DOE

Diane Dean, NIH

Michelle Bulls, NIH

Neil Thakur, NIH

Jean Feldman, NSF

Wade Wargo, ONR

Max Bernstein, NASA

Chris Saint, EPA

Cynthia Montgomery, 

USDA/NIFA

Eric Burman, EPA

Alexandra Raver, EPA

Desmond Mayes, EPA

Julie Carruthers, DOE

Jacqueline Kniskern, DOE

Thomas Griffin, DOE

Michael Zarkin, DOE

Audrey Clarke, DOT

Emily Doolittle, ED/IES

Jeffrey Johnson, HHS

Quadira Dantro, HHS

Jennifer Richards, NASA

Ann Hagan, NIH/NIGMS

Lamar Revis, NOAA

Liuyi Pei, OMB

Christine Farquharson, 

OMB

Melanie Krizmanich, 

USDA/NIFA

Mary Mahony, DHS

Barbara Orlando, DOD

Mary Tutman, OMB
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Introduction

The 2017 American Innovation and Competitiveness Act (AICA) directed the Office of Management and 

Budget (OMB), in coordination with the Office of Science and Technology Policy (OSTP), to establish an 

interagency working group (Working Group) to reduce administrative burdens on federally funded 

researchers while protecting the public interest through the transparency of and accountability for 

federally funded activities. Since the passage of AICA, OMB has released the President’s Management 

Agenda (PMA) outlining a long-term vision for modernizing the Federal Government in key areas to 

improve agencies’ ability to: deliver mission outcomes; provide excellent customer service; and 

effectively steward taxpayer dollars. The PMA also includes the Cross-Agency Priority (CAP) ResultsOriented Accountability for Grants. This CAP goal is consistent with the intent of AICA and aims to 

reduce Federal award recipient burden and better position agencies to manage awards by: improving 

the use and collection of data; creating digital tools to manage risk; and perform risk-based 

performance management. 

This report outlines ongoing efforts of the Research Business Models Working Group and governmentwide efforts associated with the PMA to improve the management of Federal awards to significantly 

reduce the regulatory burdens associated with federally funded research activities. Reducing or 

eliminating regulatory and administrative burdens that neither add value nor prevent the risk of fraud, 

waste, and abuse is critical to ensuring the health and efficiency of the Nation’s research enterprise. It 

is especially important to do so in cases where substantial and unproductive administrative burdens 

affect our Nation’s scientists, thereby impeding the rate of scientific and technological advancement –

and hence our National competitiveness. Many reports have been written and numerous Congressional 

hearings have been held on this issue over the past several decades, identifying particular regulations 

or processes and offering proposals for significant improvement. 

As required by AICA, the Working Group is expected to review the relevant regulations and recommend 

ways to minimize the burden associated with the regulations. The AICA specifically directed the Working

Group to make progress, to the extent practicable, in four areas:

1. Establishment of a centralized assurances repository;

2. Establishment of a centralized researcher profile database;

3. Development of a simplified, uniform grant application format and associated processes to 

streamline grant application and review; and

4. Simplification of mandatory progress reports, with an emphasis on performance outcomes.

The Working Group was further charged to regularly review relevant administrative regulations and 

make further recommendations to eliminate, streamline, or otherwise improve relevant regulations or 

processes, focusing on performance-based goals insofar as possible.

OMB and OSTP chose the National Science and Technology Council’s Research Business Models (RBM) 

Working Group to serve as the interagency Working Group called for in the AICA, and the agency 

members of the RBM accepted the assignment willingly. The RBM, which has been chartered since 2006, 

has the appropriate membership and authorities to carry out the mandates related to administrative 

burdens on researchers. RBM has always aimed to ensure that the business of Federal research funding 

is efficient, effective, and accountable to the American public. OMB and OSTP will collaborate closely 

to ensure that the RBM achieves all the AICA objectives assigned to the Working Group.

The RBM has previously conducted work in all four of the work areas called out in the bill, as well as 

others, and continues to work to identify additional areas for improvement. This report describes 

progress to date on those four topic areas as well as ideas for possible further activity. In conducting its 
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work, RBM routinely consults extensively with outside stakeholders, particularly professional 

organizations that represent researchers and administrators from research institutions. An important 

forum for collaboration and stakeholder feedback is the National Academies of Sciences’ (NAS) Federal 

Demonstration Partnership (FDP)1

, an NAS initiative involving 10 Federal agencies and 154 institutional 

recipients of Federal funds that is dedicated to reducing the administrative burdens associated with 

research grants and contracts. 

RBM takes a holistic approach as it explores opportunities to reduce administrative burdens. Actions 

that reduce burden on research institutions may increase burden on researchers or on the agencies that 

fund them. Conversely, actions that make Federal systems more efficient can sometimes significantly 

reduce burdens on researchers and research institutions. Recent consultation with stakeholders 

indicates that risk-based and performance-based approaches to managing Federal awards might yield 

reduced burdens on researchers, institutions, and even agencies. RBM prioritizes holistic 

improvements over those focused on researchers alone. 

The 2017 21st Century Cures Act directs OMB to establish a “Research Policy Board” (RPB) consisting of 

Federal Government and non-Federal Government members that “shall make recommendations 

regarding the modification and harmonization of regulations and policies across research funding 

agencies to ensure that that the administrative burden of such research policy and regulation is 

minimized”. The RPB would operate as a Federal Advisory Committee and would include a 

representative from RBM to ensure constructive coordination between these two bodies that share 

similar missions.

Progress Report on the Four AICA-Assigned Tasks

Establishment of a Centralized Assurances Repository

Currently, every application for a Federal grant must include a set of statements certifying or assuring 

the Federal agency that the applicant’s home institution is in compliance with all applicable laws and 

regulations. Some examples of laws and regulations an organization must certify compliance with are, 

but not limited to, the following: 

1. Will comply with all limitations imposed by annual appropriation acts.

2. Will comply with all applicable requirements of all other Federal laws, executive orders, 

regulations, and public policies governing Federal financial assistance awards and any Federal 

financial assistance project covered by this certification document, including but not limited to:

• Trafficking Victims Protection Act of 2000, as amended, 22 U.S.C. § 7104(g). 

• Drug Free Workplace Requirements for Federal Grant Recipients, 41 U.S.C. § 8103.

• Protection from Reprisal for Disclosure of Certain Information, 41 U.S.C. § 4712.

• National Environmental Policy Act of 1969, as amended, 42 U.S.C. § 4321 et seq.

• Universal Identifier and System for Award Management, 2 C.F.R. part 25. 

• Reporting Subaward and Executive Compensation Information, 2 C.F.R. part 170.

• OMB Guidelines to Agencies on Government-wide Debarment and Suspension (Nonprocurement), 2 C.F.R. part 180.

• Civil Actions for False Claims Act, 31 U.S.C. § 3730.

• False Claims Act, 31 U.S.C. § 3729, 18 U.S.C. §§ 287 and 1001.

 1 http://sites.nationalacademies.org/pga/fdp/index.htm
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• Program Fraud Civil Remedies Act, 31 U.S.C. § 3801 et seq.

• Lobbying Disclosure Act of 1995, 2 U.S.C. § 1601 et seq. 

• Title VI of the Civil Rights Act of 1964; 42 U.S.C. § 2000d et seq.

• Title VIII of the Civil Rights Act of 1968, 42 U.S.C. § 3601 et seq.

• Title IX of the Education Amendments of 1972, as amended; 20 U.S.C. § 1681 et seq.

• Section 504 of the Rehabilitation Act of 1973, as amended; 29 U.S.C. § 794.

• Age Discrimination Act of 1975, as amended 42 U.S.C. § 6101 et seq.

Several of these statutes are included in a standard certifications and representation form that many 

agencies use. The agencies may require additional certifications and representations that are specific 

to their agency or program. 

Annually, the Federal government receives over 200,000 grant applications that require the completion 

of assurances. Most organizations, particularly research organizations, submit multiple applications 

throughout the year, many of which are not funded.

The practice of providing written assurances on each grant application for government-wide 

requirements is unnecessary and duplicative. To reduce this unnecessary burden, an interagency 

working group has developed a draft government-wide annual standard set of assurances for grant 

applicants and recipients. The intent is to establish a centralized service for the collection of and access 

to government-wide assurances that apply to grants, leveraging the Integrated Award Environment

managed by the General Services Administration. As reflected in the Sharing Quality Services CAP Goal 

it is anticipated that this service will be made available in Quarter 2 of Fiscal Year 2019. Once available 

and fully implemented, grant applicants will no longer make multiple assurances on their applications; 

they would only indicate that their institution’s assurances are up to date in the centralized system. 

Federal awarding agencies will have access to the Integrated Award Environment, similar to how the 

process works for Federal procurement applicants.

This approach eliminates the need to make multiple assurances on a grant-by-grant basis and 

eliminates the need for funding agencies to review assurances on each grant application. It reduces 

duplication and paperwork, as well as significantly streamlines the relationship with awarding agencies 

across the government. It is worth emphasizing that this innovation will pertain to not just research 

grants, but all types of Federal grant applications, which means that the burden reduction will benefit 

the entire community of Federal grant applicants. With over 200,000 applications received annually 

from approximately 40,000 recipients, it is estimated that this will result in a reduction of over 150,000 

burden hours annually.

In compliance with the Paperwork Reduction Act, applicants and recipients will have a future 

opportunity to provide comments on the proposed information collection. RBM is following the 

progress of this project, will provide comments as appropriate during the public comment period, and 

will continue to track the project, as it is an important opportunity to reduce research administrative 

burdens.
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Establishment of a Centralized Researcher Profile Database

A Centralized Researcher Profile database could significantly reduce administrative burdens on 

researchers. Through work with the FDP RBM has learned several specific lessons about what a truly 

efficient and effective research profile system might look like. 

The application and reporting requirements associated with Federal research funding are only a small 

part of the administrative burden researchers face when maintaining and supplying research profile 

data, including information about their affiliations, publications, and career histories, for example. The 

various forms they must fill out typically reside in multiple, incompatible electronic systems. For 

example, researchers maintain profiles about their careers at their institutions for tenure and 

promotion, in funding databases associated with grant applications and research progress reports, and 

in publishing systems as supplements to manuscript submissions. Each new research activity or 

product results in a need to update multiple systems. 

Because researchers already use 

multiple profile systems, it is not clear 

that a new stand-alone system would 

reduce their burden or add value to 

Federal research programs. Since

much of the relevant researcherprofile data resides outside Federal 

systems, a system that focused solely 

on Federal data would not be 

comprehensive, and therefore would 

not significantly reduce researcher 

burden. Further, developing 

information systems that meet the 

needs for multiple Federal agencies 

can be expensive, both in absolute 

dollars, as well as in the staff time it 

takes to maintain multiple interagency 

agreements. Finally, since researchers 

are already tracking their profile 

information in multiple systems, 

creating a separate Federal system 

would present not just technical 

challenges, but adoption challenges 

as well. 

For the reasons described above, RBM anticipates that it is best to avoid full-scale development of a 

stand-alone system, but, instead, to adapt existing workflows and systems that researchers are already 

using. This would avoid the adoption problem and allow Federal agencies to share development costs 

across the systems that are already collecting profile data. 

A comprehensive profile system needs an accurate and low-burden method to manage information 

from multiple sources, including multiple funders (e.g. private funders, Federal funders, international 

funders). As illustrated in Figure 1, numerous types of research products and data elements of a profile 

system can interconnect through persistent identifiers. For example, funding and person information 

are listed in the metadata of a research paper, person information is listed in funding metadata, both 

Figure 1: Types of research products generated by researchers. They then 

manually manage product citations in multiple profile systems to ensure that 

each product is linked to them, their co-creators, and their funding. RBM seeks 

to combine data streams about different research products to reduce burden 

and improve accuracy. RBM is piloting ways to automatically link all of these 

pieces of information through two public-private partnerships. 
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papers and funding are listed as accomplishments of a person, etc. As many of these data elements are 

maintained on separate Internet repositories, such as publisher or funder websites, these repositories 

should all have the ability to feed a comprehensive profile system. For example, if a researcher creates 

a profile with a persistent identifier that is used by funders and publishers, those same funders and 

publishers can automatically update the researcher’s profile when they publish a paper or issue a grant. 

This automatic information exchange already works for scholarly papers that use the same universal 

identifier system (Digital Object Identifiers or DOIs). It is more difficult for funding information since 

each funder, including Federal funders, uses different information systems and identifiers. Five current 

Federal activities designed to promote a universally useful and used researcher profile system, 

including possible use of DOIs for grant applications as well as publications, are described below.

1. Piloting Ways to Manage Researcher Profile Data Through Public-Private Partnerships

RBM is monitoring cooperative public-private efforts to address the challenges above. As described 

below, NIH is currently engaged in pilots with two non-profit groups and other funders to address 

scope, effectiveness, funding information, and financing aspects of standardized systems. Together, 

these private groups have a user base many times larger than the largest Federal grants system, and 

have established relationships with other funders, academic institutions, publishers, and repositories 

that include data exchange and financial support. Thus, through these groups, the Federal government 

can move faster and cheaper by leveraging an existing user base, infrastructure, and relationships than 

it can by starting from scratch. The caveat is that collaborations with external groups will, in general, 

involve compromises on flexibility. 

Together, the FDP and NIH are exploring cooperative efforts for researcher-profile data on a pilot basis. 

RBM will track and support the pilots as appropriate. If successful, the pilots would evolve into a data 

system that benefits the public and private sectors by delivering capabilities to:

• Identify experts;

• Verify scientists’ identities and their contributions;

• Measure the impact of research investments; and

• Capture conflicts of interest and possible overlaps in funding. 

Most importantly, these pilots have the potential to reduce burden as well as potential errors that arise 

when researchers repeatedly enter their profile information into multiple electronic systems. 

Descriptions of these pilots, and some potential applications, are provided below. By the end of 

calendar year 2018, it is expected that the pilots will have developed data models and NIH will have 

begun small-scale testing of workflows for these data. RBM will follow their progress and support as 

appropriate.

2. A Pilot with ORCID to Manage Curriculum Vitae Data 

Rather than develop a profile data hub in isolation, NIH is partnering with ORCID (Open Researcher and 

Contributor Identification) to expand the ORCID data model to include additional Curriculum Vitae (CV) 

fields. The ORCID Reducing Burden and Improving Impact Tracking (ORBIT) pilot project2 will expand 

the ORCID data model, which focuses on publications, to include data elements typically found on a CV,

such as grants awarded, courses taught, presentations, university service, and other research products.

 2 https://orcid.org/content/orbit-project
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ORCID is a not-for-profit organization that 

assigns unique persistent identifiers3 to 

researchers and scholars to link 

professional activities such as publications 

and patents while removing author 

ambiguity and facilitating easier 

information searches, reporting, and 

analysis. Persistent identifiers will ensure 

that a scientist working across multiple 

arenas—e.g. journals, books, foundations, 

etc.—will have their products automatically 

and accurately attributed to them. Over 

7,000 journals use ORCID as part of their 

workflow, and with the user’s 

permission, they automatically populate 

ORCID user accounts with citations when 

publications are issued.

As shown in Figure 2, ORCID’s user base has rapidly grown since 2012 and is now more than 10 times 

larger than the user base for NIH’s electronic Research Administration (eRA Commons) system. As of 

January 2018, ORCID has over 4.5 million live ORCID accounts linked to more than 28 million different 

research outputs (e.g., publications, data sets, patents, etc.)4

. Because their user base is so much larger, 

it is more effective to develop profile systems in partnership with ORCID than tackle government system 

development and user expansion at the same time. 

NIH eRA Commons is establishing a real-time link with ORCID, which allows users to associate ORCID 

with their eRA account. Investigators are encouraged to create an ORCID profile5

, which takes about 30 

seconds (creating a fully-fleshed out profile will take more time). Participants should expect to see 

additional functionality over time, such as assistance in completing NIH applications and reports, as 

well as allowing public data on NIH grant awards to populate ORCID.

3. A Pilot with CrossRef to Create a Universal Funding Identifier

Drawing lessons from science publishers, NIH is working on a pilot program with CrossRef6 and a 

coalition of funders to create a universal funding identifier.7 Publishers maintain hundreds of separate 

information systems, but they need a universal publication identifier to track citations efficiently and 

accurately. They assign Digital Object Identifiers (DOIs) to their papers through CrossRef and thereby 

avoid making extensive revisions to their own information systems. DOIs now serve as the universal 

publication identification system for research. 

NIH believes the same can be done with DOIs across funders to create a universal grant identifier. If this 

pilot is successful, it would be simpler, cheaper, and more accurate to track products associated with 

individual grants by linking funding DOIs for publication and other research product DOIs. It would also 

be simpler, cheaper, and more accurate to compare investments across funders, because funders will 

 3 https://support.orcid.org/knowledgebase/articles/150557

4 https://orcid.org/statistics, accessed March 8, 2018. 5 https://orcid.org/register

6 https://www.crossref.org/

7 https://www.crossref.org/community/funders/

Figure 2: Growth of ORCID. ORCID has more than 10 times as many 

users as NIH’s grant system, and is growing fast.
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be using a consistent method for tracking and reporting their investments. Because the DOI system 

would overlay each funder’s existing information system, funders would not have to change their 

internal operations in any significant way. 

4. Science Experts Network Curriculum Vitae (SciENcv)

Federal agencies already have considerable 

expertise in integrating profile data from multiple 

sources to generate reports. SciENcv is a Federalgovernment-wide, electronic researcher-profile 

project that enables researchers to more easily 

create and maintain biosketches to be submitted 

with Federal grant applications and annual reports 

for the National Institutes of Health (NIH), the 

Institute of Education Sciences (IES), and, on a pilot 

basis, the National Science Foundation (NSF). It is a 

free biosketch writer that is open to all researchers 

and was first released in September 2013. It 

eliminates the need for researchers to repeatedly 

enter biosketch information and reduces the 

administrative burden associated with Federal grant 

submission and reporting requirements. 

SciENcv currently has over 86,000 users with 

biosketches across all three Federal agencies. 

SciENcv was built and is currently maintained by the 

National Center for Biotechnology Information 

(NCBI), part of NIH’s National Library of Medicine. 

SciENcv uses data feeds from the National Library 

of Medicine’s My Bibliography and PubMed 

systems, eRA Commons, and ORCID to reduce 

data-entry burden. Figure 3 shows how SciENcv 

integrates data from NIH, ORCID, and RIS-format 

user uploads from reference management 

software. SciENcv then helps users turn these data 

into biosketches for participating agencies. 

SciENcv was an early effort by RBM to harmonize 

the process for creating biosketches across 

research agencies. While it has achieved some 

successes, its burden reduction impact is limited 

by its focus on only Federal systems and reporting. 

The pilots with ORCID and CrossRef will provide 

richer data to feed SciENcv and further simplify 

biosketch creation. The ORBIT pilot will allow 

SciENcv to eventually test sending data to ORCID as 

well as drawing data down from ORCID (Figure 4). 

With bilateral data exchange, updates researchers 

SciENcv as Report Writer

integrate data and generate reports

NIH data

(My Bibliography, 

PubMed, eRA)

ORCID

ORBIT PIlot

User Upload User Upload ((RIS RIS))

Report Formats

IES Biosketch IES Biosketch NIH Biosketch NIH Biosketch NSF Biosketch NSF Biosketch

ORCID/ORBIT as profile data hub

SciENcv as report writer

Information flows across systems

Automatic updating

• Private profile systems

• Institutional systems

• Funders (DOI pilot)

• Publishers and repositories

Automatic updating

• Private profile systems

• Institutional systems

• Funders (DOI pilot)

• Publishers and repositories

Figure 4: Under the ORBIT pilot, SciENcv could test 

bilateral data exchange with ORCID. It will also be able 

to import funding DOI information through the CrossRef 

pilot via ORCID, which could support new functionality 

over time.

SciENcv as Report Writer

integrate data and generate reports

NIH data

(My Bibliography, 

PubMed, eRA)

ORCID

User Upload User Upload ((RIS RIS))

Report Formats

IES Biosketch IES Biosketch NIH Biosketch NIH Biosketch NSF Biosketch NSF Biosketch

ORCID as profile data hub

SciENcv as report writer

Automatic updating

• Private profile systems

• Institutional systems

• Funders

• Publishers and repositories

Automatic updating

• Private profile systems

• Institutional systems

• Funders

• Publishers and repositories

Figure 3: SciENcv currently integrates data from ORCID, 

NIH, and users to create biosketches. Data exchange is 

unidirectional; data do not pass from SciENcv and 

biosketches back to ORCID and other profile systems. 
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make in NIH systems could feed ORCID, and by extension, update their faculty system profiles. With 

reliable funding data coming through the CrossRef system via DOIs, the SciENcv system could 

eventually be enhanced so as to populate other grant-application sections, such as “Current and 

Pending Support.” 

5. Linking Profile Data to Maximize Results and Reduce Burden

Research products can be tracked through identifiers like Research Resource Identifiers and Digital 

Object Identifiers. People can be tracked through ORCID and funding through Digital Object Identifiers. 

This is the key to maximizing burden reduction. RBM is also working with the community to link every 

part of the research ecosystem (see Figure 1) through persistent identifiers. 

A research product identifier (e.g., a DOI for a peerreviewed journal article) can include ORCIDs of the 

creators and DOIs of the funding in their metadata. 

When such a product identifier becomes public, 

ORCID automatically includes the product citation 

in the creators ORCID profile, reducing researcher 

burden. When one product cites another (e.g., a 

paper using a dataset), those citations can also be 

tracked and used to measure impact.

By piloting development in partnership with trusted 

community-driven organizations, Federal research 

agencies can capitalize on the relationships these 

organizations already have with other data systems 

and providers (e.g., publishers, data repositories, 

and university profile systems). For example, 

publisher databases or funders can automatically 

update ORCID profiles through the DOI system, 

improving accuracy and reducing researcher 

burden. 

Through the ORBIT expansion of ORCID to 

encompass a broader range of profile data, 

researchers would continue to maintain their 

profile data in the system they wish (e.g., their 

faculty profile system). Those data can be 

integrated with all other systems, including Federal 

funders, through community partners like ORCID 

(see Figure 5). Since ORCID data are public, Federal funders can use those data, and all the links 

between products, people, and funding, to better understand the impact of Federal research 

investment. 

An added benefit to this approach is that ORCID users could share their profile data with networking 

services, leading to more efficient and equitable ways for people to find reviewers, collaborators, and 

mentors. Moreover, this richer data will make it easier for the scientific community to create measures 

and incentives for better scientific practices such as openness, rigor, and impact. 

Figure 5: ORCID can serve as a data hub for multiple 

systems, reducing burden and increasing accuracy. ORCID 

is piloting a broader data model to capture CV elements, 

including funding DOIs from the CrossRef pilot. Each profile 

system exchanges public data with ORCID, and researchers 

can use their faculty profile system draw from ORCID data to 

create reports their institution like CVs or faculty webpages. 

Faculty Profile System

integrate data and generate reports

ORCID

ORBIT Pilot

Direct Faculty 

Input & Curation

Direct Faculty 

Input & Curation

Automatic updating

• Private profile Systems

• Institution Systems

• Funders (DOI pilot)

• Publishers and repositories

Automatic updating

• Private profile Systems

• Institution Systems

• Funders (DOI pilot)

• Publishers and repositories

Outputs

Faculty 

Webpage

Faculty 

Webpage

Faculty 

Expert Locator

Faculty 

Expert Locator

Tenure formatted 

CV

Tenure formatted 

CV

ORCID/ORBIT as profile data hub 

Faculty system meet institution 

needs and formats
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Development of a Simplified and Uniform Grant Application Format and Associated 

Processes to Streamline Grant Application and Review 

1. Standardized Grants Management Business Processes

The President’s Management Agenda prioritizes reducing burden and sets a cross-agency priority goal 

specific to Results-Oriented Accountability for Grants. This builds on initial work which began in 2017,

when an interagency working group began an effort to identify a set of standard business capabilities 

for grants management, leveraging the Federal Integrated Business Framework (FIBF) model managed 

by the Unified Shared Services Management (USSM).8 This approach recognizes that much of the 

burden on recipients is a result of disparate internal business processes across the Federal government. 

Building off the standard business capabilities established in 2017, the community is currently 

developing standard data elements. This work is also leveraging the results of the DATA Act Section 5 

Pilot9 in which OMB committed to take action to continue to standardize data elements and leverage 

standardized data to eliminate unnecessary duplication in reporting. 

2. Uniform Grant Application Format

Mindful of the burdens created when grant applicants have to work with multiple, disparate grant 

application forms with varying data elements captured, and multiple, disparate agency computer 

systems, an interagency committee of approximately 15 research agencies undertook efforts to create 

a standard grant-application form in 2003 (the SF424RR, where RR stands for Research and Related). 

To date, the agencies have: 

• Identified common data elements (must have been common to at least 3 agencies);

• Developed data standards;

• Developed a modular approach to the grant application forms to optimize flexibility for

agencies while maintaining fed-wide standard approaches for the community;

• Developed standard approaches for combining fed-wide and agency specific forms to meet

the information requirements of the research agencies; and

• Developed standard help text for the fed-wide forms.

NIH and NSF, the co-chairs of the RBM interagency committee, worked closely with the Federal 

Demonstration Partnership10 to refine approaches to the electronic implementation of the forms. They 

also hold training meetings for research institutions and system-improvement discussions with both 

the applicants and Federal community members.

3. Additional Processes to Streamline Grant Applications and Review

The AICA directed the Working Group to consider:

• Procedures for preliminary project proposals;

• Increased use of “Just-in-Time” procedures for submitting documentation not directly

relevant to scientific merit; and

• Simplified initial budget submissions with detailed budget proposals for applicants identified

as likely to be funded during peer review.

8 https://www.ussm.gov/ 9

https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/sequestration_reports/2017_data_act_section5

_report.pdf

10http://sites.nationalacademies.org/pga/fdp/pga_054588 
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Several RBM member agencies have experimented with such innovations and have lessons to share 

from their experiences. RBM will explore these lessons and seek others about these approaches to 

reducing the burdens of initial applications. After assessing the available knowledge base, RBM will 

devise recommendations for how best to proceed with regard to streamlined grant applications and 

review. 

Simplification of Mandatory Progress Reports for Agency Review, with an Emphasis on 

Performance Outcomes

The current mandated progress report is the Research Performance Progress Report (RPPR), which 

resulted from an RBM initiative to create greater consistency in the administration of Federal research 

awards. It enables grantees to submit annual, interim, and final performance reports to Federal funding 

agencies that support research and research-related activities.

Until 2011, researchers who received funding from more than one Federal agency had to use a wide 

variety of reporting forms or formats to report on the progress of their federally funded award. Knowing 

that unnecessary differences in research progress reporting contributes to administrative burden in the 

research community, takes valuable research time from investigators, and increases costs involved in 

the management of research programs, RBM developed a standardized reporting format that 

researchers could use to prepare interim (e.g., annual) progress reports to any Federal agency that 

supports research. As part of the development process, a draft standardized format, the Research 

Performance Progress Report (RPPR), was published in the Federal Register for public comment. The 

input provided was fully considered as part of the finalization process. The RPPR was published in final 

form in the Federal Register on January 13, 2010. 

RPPR Report Components and Reporting Categories

Mandatory Category that must be used by all agencies:

• Accomplishments: What was done? What was learned?

Optional Categories that may be used by agencies:

• Products: What has the project produced?

• Participants & Other Collaborating Organizations: Who has been involved?

• Impact: What was the impact of the project? How has it contributed?

• Changes/Problems

• Special Reporting Requirements (where applicable)

• Budgetary Information

• Project Outcomes: What were the outcomes of the award? (for final reports only)

• Appendix: Demographic Information for Significant Contributors

RBM developed a standardized RPPR that would be both easier to produce and review. Implementation 

guidance was issued via a joint OSTP and OMB Memorandum in April 2010.11, 12 

 11 https://rbm.nih.gov/rppr_approval_memo.pdf

12 The requirement for use of the RPPR was formalized in 2 CFR 2 00.328 by stipulating that, “The Federal awarding agency 

must use standard, OMB-approved data elements for collection of performance information (including performance progress 

reports, Research Performance Progress Report, or such future collections as may be approved by OMB and listed on the OMB 

Web site).”
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The RPPR directly benefits the recipients of Federal grants and cooperative agreements by 

standardizing the types of information required in performance reports, reducing both administrative 

effort and costs. The RPPR also makes it easier to compare the results of Federal investment in research

and research-related (e.g., research training) programs across government. 

The standardized RPPR format was intended to replace other performance reporting formats currently 

in use by agencies supporting research and research-related activities. As designed and approved for 

agency implementation, the RPPR format asks researchers to report on recent progress at the 

frequency required or designated by the agency. Information, once reported, is not required to be 

submitted again for later progress reports. The RPPR was designed to be as flexible as possible and 

allow agencies to implement in a variety of formats to suit their individual needs. For example, agencies 

can use the format in either paper or electronic form, and can choose which of the optional categories 

to implement. Only one reporting category—Accomplishments—is required for all agencies in their 

implementation. 

Agency adoption of the RPPR for interim progress reports was successful and led to a revised version of 

the format being republished in the Federal Register for public comment in 2016 to incorporate lessons 

learned by agencies during the initial implementation. The feedback received was fully considered in 

development of the revised format which was published in final form in the Federal Register in 

November 2016. As part of this revision, the RPPR was expanded to allow agencies to use the format for 

final performance reports in addition to interim reports. In addition, a new optional category was added 

to the format for the researcher to provide a brief summary of the cumulative outcomes or findings of 

the project. Some agencies (e.g., NSF and NIH) now post these outcomes on their websites for access 

by the public. Currently, the following agencies have implemented or are in the process of 

implementing the RPPR: Department of Agriculture (USDA), Department of Homeland Security (DHS), 

Department of Commerce (DOC), Department of Defense (DOD), Department of Energy (DOE), 

Department of Justice (DOJ), Environmental Protection Agency (EPA), Department of Education’s IES, 

National Aeronautics and Space Administration (NASA), National Endowment for the Humanities (NEH), 

NIH (and other Public Health Service (PHS) agencies), and NSF.13

The NSF serves as the steward of the RPPR format, and all relevant documents are maintained on the 

NSF RPPR website.14 Agencies continue to be required to submit to OMB, in accordance with the 

Paperwork Reduction Act, revisions to their currently approved performance progress reporting 

information collections to comply with the uniform RPPR format. 

The RPPR consists of eight sections: two mandatory (cover page and accomplishments) and six optional 

(products; participants and other collaborating organizations; impact; changes; self-reporting

requirements; and budgetary information).15 Agencies have the ability to make any of the six optional 

sections mandatory as well as add additional questions not specified in the RPPR; this flexibility enables 

agencies to meet their needs while simultaneously reducing burden for grantees and agencies in 

preparing and reviewing progress reports. For example, NIH requires nine fields and a series of 

additional questions; NSF uses the standard RPPR format of two mandatory and six optional questions; 

USDA requires eight sections; and, the Department of Defense requires four RPPR sections and includes 

seven additional sections. The estimated time to complete the RPPR varied highly among Federal 

 13 National Science Foundation. 2017. “Research Performance Progress Report (RPPR).” Available at: 

https://www.nsf.gov/bfa/dias/policy/rppr/. 14 The NSF RPPR is available at: https://www.nsf.gov/bfa/dias/policy/rppr/index.jsp 15 National Academy of Sciences. 2016. “Optimizing the Nation’s Investment in Academic Research: A New 

Regulatory Framework for the 21st Century.” DOI: 10.17226/21824.
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agencies. For example, the NIH estimates that it will take grantees approximately 15 hours to complete 

the RPPR16 while the USDA National Institute of Food and Agriculture estimated 3.1 hours per 

response.17

Further Recommendations to Minimize Regulatory Burden While 

Emphasizing Performance 

The Working Group was further charged to regularly review relevant administrative regulations and 

make further recommendations to eliminate, streamline, or otherwise improve relevant regulations or 

processes, focusing on performance-based goals insofar as possible. The RBM has identified two areas 

in which there is opportunity for improvement based upon recommendations for reducing regulatory 

burden for Federally funded researchers made by three major reports—by the National Science 

Board18, the National Academy of Sciences19, and the Government Accountability Office20 (see Appendix 

1). 

As a start, based on an initial assessment of these reports, RBM plans to examine options to reduce 

burdens associated with the following, which were identified in all three major reports as significantly 

burdensome and minimally helpful. 

Clarify Responsibilities for Monitoring Subrecipients

OMB’s 2014 Uniform Guidance (2 CFR 200)21 (UG) aimed to reduce administrative burden associated 

with Federal awards while reducing the risk of waste, fraud, and abuse. When issuing the UG, OMB 

allows for recipients to take a risk based approach to monitoring subrecipients. For instance, if a 

subrecipient is subject to (and in good standing in) the single audit, a pass-through entity may monitor 

a subrecipient less, recognizing that recipients must prioritize oversight of those subrecipients who are 

or higher risk. Reports from the field indicate that institutions (as pass-through entity) still feel they are 

responsible for separately auditing sub-recipients who are subject to the single audit or resolving cross 

cutting audit findings that do not pertain to their specific sub-award. Thus, they are still undertaking 

additional responsibilities that are not required. 

RBM has agreed to investigate the factors that have inhibited the intended effect of the UG language on 

sub-recipient monitoring. The committee will then offer recommendations about what can be done to 

clarify the intent and reduce unnecessary, duplicative monitoring activities, which will reduce this 

administrative burden, enabling grantees to devote more attention to research performance and 

results. 

 16 National Institutes of Health. 2017. “NIH and Other PHS Agency Research Performance Progress Report (RPPR) 

Instruction Guide.” Available at: https://grants.nih.gov/grants/rppr/rppr_instruction_guide.pdf. 17 Federal Register. 2017. “Submission for OMB Review; Comment Request. A notice by the Agriculture 

Department on 05/02/2017.” Available at: https://www.gpo.gov/fdsys/pkg/FR-2017-05-02/pdf/2017-08788.pdf. 18https://www.nsf.gov/pubs/2014/nsb1418/nsb1418.pdf

19 https://www.nap.edu/catalog/21824/optimizing-the-nations-investment-in-academic-research-a-newregulatory

20 https://www.gao.gov/products/GAO-16-573 21 https://www.ecfr.gov/cgi-bin/textidx?SID=9753a50d824a942cb367a62721b97431&mc=true&node=pt2.1.200&rgn=div5
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Improve Grantee Financial Conflict of Interest (FCOI) Regulations 

Section 200.112 of the UG requires that agencies establish conflict of interest policies for Federal 

awards. To comply with this requirement, agencies have in turn drafted and implemented policies 

applicable to their agency awards. However, there is no single Federal policy for what constitutes a 

financial conflict of interest. As a result, agencies have adopted differing and, in some cases, 

inconsistent FCOI reporting requirements, forcing researchers and their sponsored programs offices 

to maintain awareness of a range of requirements and to develop systems to accommodate all of 

them. 

RBM will examine the studies of the effectiveness of FCOI policies as well as the associated burdens 

and consider ways to harmonize requirements across agencies so as to reduce burdens.

Conclusion

Research regulations and procedures are necessary to ensure safety and promote efficiency and 

effectiveness of federally funded research projects, as well as to prevent fraud, waste, and abuse. 

However, incompatible reporting systems and requirements and excessively elaborate forms consume 

researcher time and effort without yielding significant benefits. 

In support of activities specified in AICA’s four topic areas, RBM has introduced and supported a 

variety of interagency projects, including efforts to create a centralized researcher profile database 

and a current pilot program, and developing a simplified and uniform grant application format. These 

efforts coupled with those to establish a centralized assurances repository and streamlined 

mandatory progress reports for agency review exemplify RBM’s commitment to fully achieving AICA’s 

priorities, reducing impediments to American science and technology advancements, and improving 

our Nation’s economic competitiveness. Across the coming year, the RBM will make advances on the 

topics described in this report and identify additional areas to reduce bureaucracy and return 

invaluable time to the Nation’s researchers and innovators. 
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Appendix 1

Summary of Recommendations from Recent Reports on Reducing Administrative Burdens to 

Researchers and Research Institutions

Reducing Investigators’ Administrative Workload for Federally Funded Research (March 

2014)

The National Science Board identified a number of areas that applicants and awardees considered to 

be sources of heavy administrative workload, including financial management, grant proposals and 

processing, progress reports, human subjects’ research, time and effort reporting, animal welfare, 

personnel management, subcontracts, financial conflict of interest reporting, and laboratory safety and 

security. The Board urged Federal agencies to:

• “Focus on the Science” by simplifying grant proposals and progress reports, for example, by 

significantly reducing requirements that are not critical to a proposals merit review until the 

proposal has been positively reviewed and is being considered for funding.

• “Eliminate or Modify Ineffective Regulations” by re-evaluating approaches to time and effort 

reporting as well as to human subjects’ protection, conflict of interest reporting, and safety 

and security requirements. Removing these burdens would simultaneously accelerate the 

pace of scientific discovery and innovation.

• “Harmonize and Streamline Requirements” for grant proposals and management, as the lack 

of consistency and standardization comes at a high cost to investigators and institutions. 

Several aspects of this could be addressed through a high-level, inter-agency, inter-sector, 

multi-stakeholder committee.

• “Increase University Efficiency and Effectiveness” through dissemination of effective practices 

and models, such as through Federal agency collaboration with stakeholders to identify and 

disseminate best practices. 

Optimizing the Nation’s Investment in Academic Research: A New Regulatory Framework 

for the 21st Century (2016)

A panel convened by the National Academies of Science provided a comprehensive review, describing 

in detail ways that the government-research university partnership is “under stress.” They expressed 

that “Federal laws, regulations, rules, policies, guidance, and reporting requirements, while essential 

to a well-functioning, responsible system of research, have led over time to an environment wherein a 

significant percentage of an investigator’s time is complying with regulations, taking valuable time 

away from research, education, and scholarship.” The NAS authors offered a number of valuable 

overarching insights with regards to this landscape: 1) There is value in collecting and analyzing data 

on the cumulative effect of research regulations; 2) There is a need to identify and consider unintended 

consequences; 3) Academic research institutions are diverse—in geographic location, public or private 

status, size, legal structure, mission, financial and physical resources, and research interests. This 

diversity affects the ability of institutions to respond to regulatory requirements; 4) Academic research 

institutions often receive funding from different Federal agencies that at times issue inconsistent, 

duplicative, or unclear regulations and policies; and 5) Some academic institutions and research 

communities have failed to adequately address transgressions or failures of scientists to meet 

reasonable standards and norms. Their recommendations are highlighted below, and for each, specific 

and detailed actions were recommended in their full report:
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• The regulatory regime governing federally funded academic research should be critically 

reexamined and recalibrated.

• Research institutions must demand the highest standards in institutional and individual 

behavior, and those universities that deviate from or fail to enforce the norms of behavior 

should be sanctioned.

• Creation of a new mechanism, to include an active public-private forum and a designated 

official within government, to foster a more effective conception, development, and 

harmonization of research policies.

Opportunities Remain for Agencies to Streamline Administrative Requirements (July 2016)

The US Government Accountability Office (GAO) issued a report that investigated research grant 

requirements and their administrative workloads and costs. It also examined: (1) the sources and goals 

of selected requirements, (2) factors affecting universities' administrative workload and costs for 

complying with the requirements, and (3) efforts by OMB and research funding agencies to reduce the 

requirements' administrative workload and costs, and the results of these efforts. GAO selected and 

examined in detail nine areas of administrative requirements at DOE, NASA, NIH, and NSF, and 

interviewed administrative staff and researchers from six universities. GAO selected agencies and 

universities ranged in the amount and type of research funding provided or received. The report was 

based on interviews of officials from universities and stakeholder organizations. The interviewees 

identified three common factors that in their view unnecessarily add administrative workload:

• Variations in agencies’ requirements;

• Pre-award documentation requirements that accompany grant proposals; and

• Increased prescriptiveness of certain requirements.

The GAO noted that OMB and research funding agencies are already taking steps to standardize 

requirements, to postpone certain pre-award requirements, and to allow universities greater 

flexibilities, yet states that “opportunities exist in each of the three areas to further reduce universities’ 

administrative workloads and costs.” Nine specific recommendations were made for executive action, 

identifying additional areas where requirements, such as those for budgets or purchases, can be 

standardized, postponed, or made more flexible, while maintaining oversight of Federal funds. DOE, 

NASA, and NIH generally concurred, and OMB and NSF did not comment on the recommendations.