FEDERAL 

RESEARCH 

GRANTS

Opportunities Remain 

for Agencies to 

Streamline 

Administrative 

Requirements

Report to Congressional Requesters

June 2016

GAO-16-573

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-573, a report to 

congressional requesters

June 2016

FEDERAL RESEARCH GRANTS

Opportunities Remain for Agencies to Streamline 

Administrative Requirements

Why GAO Did This Study

The federal government obligated over

$27 billion for university research in 

fiscal year 2015, according to NSF. To 

allow for oversight of these funds, 

Congress and research funding 

agencies established administrative 

requirements that universities must 

comply with as part of grants they 

apply for and receive. University 

stakeholders have studied and raised 

concerns about the workload and costs 

to comply with the requirements. 

GAO was asked to review research 

grant requirements and their 

administrative workloads and costs. 

This report examines (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 that ranged in the 

amount and type of research funding 

provided or received.

What GAO Recommends

GAO recommends that OMB, DOE, 

NASA, NIH, and NSF identify

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.

What GAO Found

Administrative requirements for federal research grants include (1) Office of 

Management and Budget (OMB) government-wide grant requirements for

protecting against waste, fraud, and abuse of funds and (2) agency-specific 

requirements generally for promoting the quality and effectiveness of federally

funded research. For example, OMB requires grantees to maintain records 

sufficient to detail the history of procurement for all purchases made with grant 

funds, and the Department of Energy (DOE), National Aeronautics and Space 

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

Foundation (NSF) require applicants to develop and submit biographical 

sketches describing their professional accomplishments so agencies can 

consider researchers’ qualifications when deciding which proposals to fund.

Officials from universities and stakeholder organizations GAO interviewed

identified common factors that add to their administrative workload and costs for 

complying with selected requirements: (1) variation in agencies’ implementation 

of requirements, (2) pre-award requirements for applicants to develop and submit 

detailed documentation for grant proposals, and (3) increased prescriptiveness of 

certain requirements. They said that these factors add to universities’ workload 

and costs in various ways, such as by causing universities to invest in new 

electronic systems or in the hiring or training of staff. For example, university 

officials told GAO that new OMB requirements for purchases made with grant 

funds will result in added costs for hiring administrative staff to handle an 

increased volume of purchases that are subject to some form of competition.

OMB and research funding agencies have made continuing efforts to reduce 

universities' administrative workload and costs for complying with selected 

requirements, with limited results. These included efforts in three areas: 

(1) standardizing requirements across agencies; (2) postponing certain preaward requirements until after making a preliminary decision about an applicant’s 

likelihood of funding; and (3) in some cases, allowing universities more flexibility 

to assess and manage risks for some requirements. For example, funding 

agencies have developed a standard set of administrative terms and conditions 

for research grants and a standard form for research progress reports. Such 

efforts are in accordance with federal goals, such as those in a 2011 executive 

order that calls for agencies to harmonize regulations and consider regulatory 

approaches that reduce burdens and maintain flexibility. However, opportunities 

exist in each of the three areas to further reduce universities’ administrative 

workload and costs. First, efforts to standardize requirements have not fully 

addressed variations in agency implementation of requirements, such as 

agencies’ forms and systems for collecting project budgets and biographical 

sketches. Second, funding agencies have not fully examined pre-award 

requirements to identify those—such as requirements for detailed budgets—that 

can be postponed. Third, some requirements—such as those for obtaining 

multiple quotations for small purchases—limit universities’ flexibility to allocate 

administrative resources toward oversight of areas at greatest risk of improper 

use of research funds. Further efforts to standardize requirements, postpone preaward requirements, and allow more flexibility for universities could help ensure 

agencies do not miss opportunities to reduce administrative workload and costs.

View GAO-16-573. For more information, 

contact John Neumann at (202) 512-3841 or 

neumannj@gao.gov.
Page i GAO-16-573 Federal Research Grants

Letter 1

Background 6

OMB’s Government-Wide Requirements Generally Govern the 

Proper Use of Grant Funds, and Agency-Specific Requirements 

Generally Govern Research Quality and Effectiveness 12

Selected Universities Identified Common Factors That Add to 

Their Workload and Costs for Complying with Selected 

Administrative Requirements 16

OMB and Funding Agencies Have Made Continuing Efforts to 

Reduce Universities’ Administrative Workload and Costs, with 

Limited Results 25

Conclusions 40

Recommendations for Executive Action 41

Agency Comments and Our Evaluation 42

Appendix I Objectives, Scope, and Methodology 46

Appendix II Sources and Goals of Selected Administrative Requirements 50

Appendix III Examples of Differences in Selected Administrative Requirements 

across Agencies in GAO’s Review 54

Appendix IV Office of Management and Budget and Selected Research 

Funding Agency Efforts to Reduce Administrative Workload and 

Costs Related to Selected Requirements 58

Appendix V Comments from the Department of Energy 66

Appendix VI Comments from the Department of Health and Human Services 68

Contents
Page ii GAO-16-573 Federal Research Grants

Appendix VII Comments from the National Aeronautics and Space Administration 72

Appendix VIII GAO Contact and Staff Acknowledgments 74

Tables

Table 1: Selected Federal Goals and Directives Related to 

Streamlining Administrative Requirements on Grants 11

Table 2: Selected OMB and HHS Requirements That Have 

Become More Prescriptive 21

Table 3: Sources and Goals of Selected Administrative 

Requirements 50

Table 4: Examples of Differences in Selected Administrative 

Requirements across Agencies in GAO’s Review 54

Table 5: Examples of OMB and Selected Research Funding 

Agency Efforts to Standardize Selected Administrative 

Requirements 58

Table 6: Examples of Selected Research Funding Agency Efforts 

to Streamline Selected Pre-Award Administrative 

Requirements through Preliminary Proposals 61

Table 7: Examples of OMB and Selected Research Funding 

Agency Efforts to Allow Grantees Flexibility Related to 

Selected Administrative Requirements 63

Figures

Figure 1: Federal Obligations for Research at Universities and 

Colleges, by Agency, in Billions, Fiscal Year 2015 6

Figure 2: Sources of Selected Federal Research Requirements 

and Key Administrative Tasks for Complying with Them 

over the Grant Life Cycle 8
Page iii GAO-16-573 Federal Research Grants

Abbreviations

DOE Department of Energy

HHS Department of Health and Human Services

NASA National Aeronautics and Space Administration

NIH National Institutes of Health

NSF National Science Foundation

OMB Office of Management and Budget

OSTP Office of Science and Technology Policy

RBM Research Business Models working group

SF-424 Standard Form 424

Uniform Guidance Uniform Administrative Requirements, Cost 

Principles, and Audit Requirements for Federal 

Awards

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

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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Page 1 GAO-16-573 Federal Research Grants

441 G St. N.W.

Washington, DC 20548

June 22, 2016

The Honorable Barbara Comstock

Chairwoman

Subcommittee on Research and Technology

Committee on Science, Space, and Technology

House of Representatives

The Honorable Mo Brooks

House of Representatives

The Honorable Larry Bucshon

House of Representatives

University research contributes to American competitiveness and 

leadership in science, and the federal government has long played a 

central role in funding and setting priorities for university research.1

According to National Science Foundation (NSF) data, the federal 

government funds the majority of research performed by colleges and 

universities, obligating over $27 billion for such research in fiscal year 

2015.2 Many agencies fund specific types of research to support their 

missions. For example, the National Institutes of Health (NIH) within the 

Department of Health and Human Services (HHS) funds research into 

new medical treatments, and the Department of Energy (DOE) funds 

research into clean energy technologies. NSF funds a wide range of 

research as part of its mission to promote the progress of science in 

general.

 1

Federal agencies provide research funding through several mechanisms, including 

grants, cooperative agreements, and contracts. We focused our review on agencies’ use 

of grants and cooperative agreements to fund research and, for purposes of our report, 

refer to both mechanisms as grants. Agencies in our review provide the majority of their 

research funding to universities through grants and cooperative agreements, according to 

officials.

2

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

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

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

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

purposes of our report, we refer to these generally as research funding. NSF’s data for 

fiscal year 2015 are preliminary.

Letter
Page 2 GAO-16-573 Federal Research Grants

To allow for oversight of federal research funding, Congress and federal 

agencies have established a variety of administrative requirements for the 

use of these funds.3 Some requirements were established or 

strengthened in response to cases of researchers improperly spending 

funds or out of concerns about the integrity of the research being 

conducted. Others were established to meet broader policy objectives, 

such as increasing access to research data and results. University 

administrators and researchers must comply with certain requirements 

when developing and submitting grant applications and with others as 

part of the terms and conditions of any awards they receive. For example, 

agencies generally require that applicants provide biographical sketches 

describing their professional accomplishments when submitting grant 

proposals, and require that grantees document the personnel expenses—

such as researcher salaries—and the purchases—such as equipment 

and supplies—charged to a grant.

During the last two decades, organizations that have studied these 

administrative requirements have raised concerns about the workload 

and costs for researchers and universities to comply with the 

requirements and about the effect of requirements on researchers’ ability 

to efficiently conduct research. For example, the National Science Board 

reported in 2014 that the administrative workload placed on federally 

funded researchers is more than needed to ensure accountability, 

transparency, and safety.4 This report, based on a survey of federally 

funded researchers and on discussions with universities’ administrative 

staff members, recommended that agencies take actions to reduce the 

administrative workload associated with applying for grants and reporting 

on research progress, eliminate or modify ineffective requirements, and 

improve coordination and harmonization of similar requirements across 

funding agencies. Other organizations representing the university 

research community have raised similar concerns.

 3

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

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

provisions as “requirements.”

4

National Science Board, Reducing Investigators’ Administrative Workload for Federally 

Funded Research, NSB-14-18 (Mar. 10, 2014). The National Science Board establishes 

the policies of NSF within the policy framework set forth by the President and Congress, 

and serves as an independent policy advisory body to the President and Congress on 

science and engineering research and education issues.
Page 3 GAO-16-573 Federal Research Grants

Several executive orders and a presidential memorandum have called for 

streamlining regulations and guidance to reduce grant recipients’

administrative workload and costs. For instance, Executive Order 13563 

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

reduce costs and simplify and harmonize rules, and for agencies to 

identify and consider regulatory approaches that reduce burdens and 

maintain flexibility. In addition, in December 2013, the Office of 

Management and Budget (OMB) consolidated its grants management 

circulars into a single document—the Uniform Administrative 

Requirements, Cost Principles, and Audit Requirements for Federal 

Awards (Uniform Guidance)—to streamline its guidance, promote 

consistency among grantees, and reduce administrative burden on 

nonfederal entities, as well as to strengthen oversight of federal funds to 

reduce risk of waste, fraud, and abuse.5 Despite these and other federal 

efforts to streamline research requirements, universities and stakeholder 

organizations continue to cite increasing administrative workload and 

costs for complying with requirements. Federal agencies reimburse 

universities for their administrative costs up to a cap established in OMB 

guidance, and universities pay the remainder.

6

You requested that we review requirements on federal research funding 

that create administrative workload and costs for universities. This report 

examines (1) the sources and goals of selected research grant 

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

workload and costs for complying with these requirements, and (3) efforts 

OMB and research funding agencies have made to reduce the 

 5

The Uniform Guidance is implemented through individual federal agency regulations that 

were to take effect no later than December 26, 2014. OMB developed the Uniform 

Guidance with input from the Council on Financial Assistance Reform, an interagency 

council that OMB established in October 2011 and that has led several efforts to improve 

delivery, management, coordination, and accountability of federal grants and cooperative 

agreements. The council is composed of the eight largest federal grant-making agencies 

and one rotating small grant-making agency. Office of Management and Budget, Creation 

of the Council on Financial Assistance Reform, OMB Memorandum M-12-01 (Washington, 

D.C.: 2011).

6

We have previously reported on agencies’ reimbursement of administrative and other 

indirect costs associated with university research. See GAO, University Research: Policies 

for the Reimbursement of Indirect Costs Need to Be Updated, GAO-10-937 (Washington, 

D.C.: Sept. 8, 2010).
Page 4 GAO-16-573 Federal Research Grants

administrative workload and costs for complying with these requirements, 

and the results of these efforts.

We selected and examined in detail administrative requirements in nine 

categories that multiple universities and university stakeholder 

organizations have cited as contributing to universities’ administrative 

workload and costs, have been the subject of recent streamlining efforts 

or changes in OMB or agency guidance,7 or have been part of the 

findings of recent reports by agency inspectors general. For example, 

these include requirements related to research project budgets, research 

personnel, and oversight of subrecipients. Our findings from our reviews 

of these requirements cannot be generalized to all administrative 

requirements.

To examine the sources and goals of selected requirements, we reviewed 

guidance documents, regulations, Federal Register notices, and other 

documentation of research requirements at OMB and four research 

funding agencies: DOE, the National Aeronautics and Space 

Administration (NASA), NIH, and NSF. We selected NIH and NSF 

because they are the two largest funders of research at universities and 

colleges, according to NSF data. We selected DOE and NASA as 

examples of agencies with smaller amounts of university research funding 

and different types of research. According to the NSF data, these four 

agencies provided about 83 percent of federal funding for research at 

universities and colleges in fiscal year 2015. We interviewed officials from 

these agencies and from their offices of inspector general on the sources 

and goals of these requirements. Our findings from our reviews of these 

four agencies cannot be generalized to all agencies that fund research.

To examine the factors that contribute to universities’ administrative costs 

for complying with selected requirements, we selected a nongeneralizable 

sample of six public and private universities that range in the amount of 

research funding they receive and other characteristics. We identified and 

selected these universities using NSF data on federal research funding 

provided to universities, information on their membership in the Federal 

 7

For the purposes of this report, we use the term guidance to refer to agency and OMB 

regulation, formal policy, and informal policy.
Page 5 GAO-16-573 Federal Research Grants

Demonstration Partnership,8 and audit reports on university research 

grants conducted by agencies’ inspectors general. We conducted indepth interviews with administrative staff and researchers from these 

universities to collect qualitative information on the types of administrative 

workload and costs resulting from selected requirements, and we 

reviewed university policies and documentation related to their processes 

for complying with selected requirements. We also interviewed officials 

from several university stakeholder organizations. We identified these 

organizations based on discussions with agency officials and reviews of 

published reports, and selected those organizations that had studied 

administrative workload and costs related to our selected categories of 

requirements.

To examine the efforts that OMB and research funding agencies have 

made to reduce the administrative costs of complying with selected 

requirements and the results of these efforts, we interviewed officials from 

selected universities and stakeholder organizations about OMB and 

funding agency efforts, the efforts’ effects on universities’ administrative 

workload and costs, and universities’ and stakeholder organizations’

suggestions for further efforts. We interviewed agency officials and 

reviewed agency documents regarding processes for developing and 

modifying requirements and efforts to reduce the costs of complying with 

requirements. We also interviewed staff from OMB and the Office of 

Science and Technology Policy (OSTP) about their roles in establishing 

and coordinating government-wide research policies. For more 

information on our scope and methodology, including a full list of the 

universities and stakeholder organizations included in our review, see 

appendix I.

We conducted this performance audit from April 2015 to June 2016 in 

accordance with generally accepted government auditing standards. 

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

 8

The Federal Demonstration Partnership is a cooperative initiative of 10 federal agencies 

and 155 institutional recipients of federal funds, whose purpose is to reduce the 

administrative burdens associated with research grants and contracts. The Federal 

Demonstration Partnership has initiated several efforts, in coordination with federal 

agencies, to pilot streamlined approaches for administering research grants over the past 

three decades. In some cases, these pilots have become the basis for broader reforms of 

agencies’ research grant requirements. The Federal Demonstration Partnership is 

sponsored in part by the National Academies.
Page 6 GAO-16-573 Federal Research Grants

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.

More than two dozen federal agencies use grants and other mechanisms 

to fund research at universities and colleges, as well as at other nonprofit 

and for-profit organizations, in support of agency missions related to 

public health, energy security, and space exploration, among others. NIH 

provides more than half of all federal funds for university and college 

research, and NSF, DOE, NASA, and other agencies provide the 

remaining funding (see fig. 1).

Figure 1: Federal Obligations for Research at Universities and Colleges, by Agency, 

in Billions, Fiscal Year 2015

Note: National Science Foundation data for fiscal year 2015 are preliminary.

OSTP is responsible for advising the President on the federal budget for 

research and shapes research priorities across agencies with significant 

portfolios in science and technology. OSTP also helps develop and 

implement government-wide science and technology policies and 

coordinate interagency research initiatives. OMB is responsible for 

developing government-wide policies to ensure that grants—including 

grants for research and for other purposes such as housing, education, 

transportation, and health care—are managed properly and that grant 

funds are spent in accordance with applicable laws and regulations. For 

Background
Page 7 GAO-16-573 Federal Research Grants

decades, OMB has published guidance in various circulars to aid grantmaking agencies with such subjects as record keeping and the 

allowability of costs, which for research grants may include researcher 

salaries and wages, equipment, travel, and other costs.9 Congress may 

pass laws establishing additional reporting and oversight requirements on 

grant-making agencies and grantees. Funding agencies implement these 

requirements through regulations, agency guidance, and the terms and 

conditions of grant awards. In addition, funding agency offices of 

inspector general may conduct audits to evaluate grantee compliance 

with requirements. When audits result in findings of noncompliance, such 

as grantees charging unallowable costs to grants, grantees may need to 

repay funding agencies for these costs.

Competitively awarded federal research grants generally follow a life 

cycle comprising various stages—pre-award, award, post-award 

implementation, and closeout. For competitive research grant programs, 

in the pre-award stage, a funding agency notifies the public of the grant 

opportunity through an announcement, and potential recipients submit 

applications for agency review. In the award stage, the agency identifies 

successful applicants and awards funding. The post-award 

implementation stage includes payment processing, agency monitoring,

and recipient reporting, which may include financial and performance 

information. Grant closeout includes preparation of final reports and 

financial reconciliation. Over this life cycle, applicants and recipients must 

complete various administrative tasks in order to comply with OMB and 

funding agency requirements, particularly in the pre-award and postaward implementation stages. See figure 2 for an overview of the 

administrative tasks associated with our nine selected categories of 

requirements across the grant life cycle.

 9

In 1971, OMB published standards for establishing consistency and uniformity in the 

administration of grants and other types of financial assistance to state and local 

governments and certain Indian tribunals. The first circular was No. A-102, Uniform 

Administrative Requirements for Grants-In-Aid to State and Local Governments. In 1976, 

OMB published Circular No. A-110, Uniform Administrative Requirements for Grants and 

Agreements with Institutions of Higher Education, Hospitals and Other Nonprofit 

Organizations. Other key circulars and guidance include OMB Circulars Nos. A-21, A-87, 

and A-122, establishing principles for determining costs applicable to grants, contracts, 

and other agreements with educational institutions; state, local, and tribal governments; 

and nonprofit organizations, and OMB Circular No. A-133, setting standards for obtaining 

consistency and uniformity among federal agencies for the audit of states, local 

governments, and nonprofit organizations expending federal awards.
Page 8 GAO-16-573 Federal Research Grants

Figure 2: Sources of Selected Federal Research Requirements and Key Administrative Tasks for Complying with Them over 

the Grant Life Cycle

Notes: Funding agencies and OMB have requirements that apply to grantees at the award and 

closeout stages, but we did not focus our review on requirements at these stages. This figure 

describes the tasks OMB and agencies generally require of applicants and grantees. Specific tasks 

vary depending on agencies’ implementation of requirements, and not every agency has established 

requirements for every category shown.
Page 9 GAO-16-573 Federal Research Grants

a

OMB consolidated its grants management circulars into a single document, Uniform Administrative 

Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) in 

2013. 78 Fed. Reg. 78,590 (Dec. 26, 2013).

b

The Federal Funding Accountability and Transparency Act of 2006, as amended, contains 

government-wide subaward reporting requirements, including that recipients report subaward 

information and agencies make it available on a public website in the same manner as data regarding 

other federal awards.

c

In some cases, funding agencies established requirements in their guidance in response to specific 

executive or legislative directives. For example, agencies developed requirements for managing and 

sharing research data and results to implement a 2013 Office of Science and Technology Policy 

memorandum directing agencies to support increased public access to the results of federally funded 

research. In addition, in the America Creating Opportunities to Meaningfully Promote Excellence in 

Technology, Education, and Science Act of 2007, Congress directed the National Science Foundation 

(NSF) to require postdoctoral mentoring plans in any proposals that include postdoctoral researchers.

d

The Uniform Guidance contains a general provision for agencies to establish policies that apply to 

conflicts that might arise around how recipients expend award funds. Nevertheless, we categorized 

the source of conflict of interest requirements as agency-specific guidance, because agencies have 

established specific requirements for how grantees must identify and manage conflicts of interest.

e

The National Institutes of Health requires institutions to review financial interests to identify conflicts 

and develop a plan to manage them prior to expending award funds, but not necessarily prior to 

award. Similarly, NSF requires institutions to manage, reduce, or eliminate conflicts of interest prior to 

expending award funds, but not necessarily prior to award.

Stakeholder organizations representing universities and federal agencies 

have raised concerns about the administrative workload and costs for 

complying with federal research requirements, and they have issued 

several reports with recommendations for agencies to modify 

requirements in order to achieve their goals while reducing administrative 

workload and costs. For example, in 2012, the Federal Demonstration 

Partnership surveyed principal investigators of federally funded research 

projects.10 The report on this survey found that principal investigators 

estimated they spent, on average, 42 percent of their time meeting 

requirements—including those associated with pre- and post-award 

administration and preparation of proposals and reports—rather than 

conducting active research.11 However, the survey did not specify how 

much of this time was due to administrative tasks driven by universityspecific processes or policies rather than federal requirements, or to 

nonadministrative tasks that contribute to the scientific aspects of the 

 10NIH defines a principal investigator as the individual designated by the grantee 

institution (or applicant organization) to have the level of authority and responsibility to 

direct the project or program to be supported by the grant award.

11Federal Demonstration Partnership, 2012 Faculty Workload Survey: Research Report, 

(April 2014). The study’s authors solicited responses from 53,428 principal investigators 

and received an overall response rate of 31 percent.
Page 10 GAO-16-573 Federal Research Grants

research, such as writing scientific material for proposals and reports. In 

addition, the survey did not include universities’ administrative research 

staff members, who help universities comply with federal and other 

administrative requirements on research awards. In March 2013, the 

National Science Board issued a request for information to identify which 

federal agency and institutional requirements contribute most to principal 

investigators’ administrative workload, and conducted a series of 

roundtable discussions with faculty and administrators. The board found 

that the most frequently cited areas associated with high administrative 

workload included financial management, the grant proposal process, 

progress and other outcome reporting, and personnel management, 

among others.12

There has been a series of legislative and executive goals and directives 

for agencies to simplify aspects of the grants management life cycle and 

minimize administrative burden for grantees, particularly those that apply 

for and obtain grants from multiple federal agencies. Table 1 lists several 

of these goals and directives related to streamlining administrative grant 

requirements.

 12National Science Board, Reducing Investigators’ Administrative Workload for Federally 

Funded Research. The study’s authors issued a request for information, through NSF, to 

principal investigators with federal research funding. They reported receiving 210 

responses: 192 from individuals, 12 from institutions providing institutional responses, and 

6 from stakeholder organizations providing responses on behalf of their members, which 

may have been based on a survey the organizations conducted. The report did not specify 

how many individuals received the request for information or what the overall response 

rate was. The study’s authors also conducted a series of roundtable discussions with over 

200 faculty and administrators.
Page 11 GAO-16-573 Federal Research Grants

Table 1: Selected Federal Goals and Directives Related to Streamlining Administrative Requirements on Grants 

Source Streamlining goal or directive

Federal Financial Assistance 

Management Improvement Act of 

1999a (November 20, 1999)

The act’s purpose was to improve the effectiveness and performance of federal financial 

assistance programs, simplify federal financial assistance application and reporting 

requirements, improve the delivery of services to the public, and facilitate greater coordination 

among those responsible for delivering such services. The act required agencies to establish a 

common application reporting system, including uniform administrative rules for federal 

financial assistance programs.

Executive Order 13563 (January 18, 

2011)

The order calls for greater coordination across agencies to reduce redundant, inconsistent, or 

overlapping regulatory requirements.

The order also calls for agencies to (1) identify and consider regulatory approaches that 

reduce burdens and maintain flexibility and freedom of choice for the public, where relevant, 

feasible, and consistent with regulatory objectives, and to the extent permitted by law; and (2) 

consider how best to promote retrospective analysis of rules that may be outmoded, 

ineffective, insufficient, or excessively burdensome, and to modify, streamline, expand, or 

repeal them accordingly.

Presidential Memorandum on 

Administrative Flexibility, Lower 

Costs, and Better Results for State, 

Local, and Tribal Governments 

(February 28, 2011)

This memorandum directs the Office of Management and Budget (OMB) to review and where 

appropriate revise guidance concerning grants and other financial assistance awards—

including grants to universities—in order to eliminate, to the extent permitted by law, 

unnecessary, unduly burdensome, duplicative, or low-priority recordkeeping requirements and 

effectively tie such requirements to achievement of outcomes.

Digital Accountability and 

Transparency Act of 2014

(May 9, 2014)

The act’s purposes include simplifying reporting for entities receiving federal funds by 

streamlining reporting requirements and reducing compliance costs while improving 

transparency. It requires OMB to (1) review the information required to be reported by 

recipients of federal awards to identify unnecessarily duplicative or burdensome reporting 

requirements, and (2) establish a pilot program to address such unnecessary duplication in 

financial reporting and reduce compliance costs for recipients of federal awards.

Source: GAO analysis of laws, executive orders, and a presidential memorandum. | GAO-16-573

a

The act—commonly referred to by the grants community as P.L. 106-107—expired in 2007, but a 

number of reform initiatives that began in response to the act continue. As defined in the act, “federal 

financial assistance” includes grants, cooperative agreements, loans, loan guarantees, insurance, 

interest subsidies, and other forms of assistance. Pub. L. No. 106-107, § 4(3), 113 Stat. 1486 1487 

(1999), citing 31 U.S.C. § 7501(a)(5).

There have also been several recent directives intended to strengthen 

accountability over federal funds. For example, Executive Order 13520 of 

November 20, 2009 adopts a set of policies for transparency and public 

scrutiny of significant payment errors throughout the federal government 

and for identifying and eliminating the highest improper payments.

In response to such streamlining and accountability directives, in 

December 2013, OMB consolidated its grants management circulars into 

a single document, the Uniform Guidance. The requirements in the 

Uniform Guidance apply broadly to different types of grantees—including 

state, local, and tribal governments, institutions of higher education, and 

nonprofit organizations—and different types of grants—including grants 

for research or other purposes. The Uniform Guidance is implemented 
Page 12 GAO-16-573 Federal Research Grants

through individual federal agency regulations that were to take effect no 

later than December 26, 2014.13 When issuing the final guidance, OMB 

stated that it would (1) monitor the effects of the reforms in the Uniform 

Guidance to evaluate the extent to which the reforms were achieving their 

desired results for streamlining and accountability and (2) consider 

making further modifications as appropriate.

Selected administrative requirements in OMB’s government-wide grant 

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

funds. These include requirements we selected related to competing and 

documenting purchases, documenting personnel expenses, preparing 

and managing project budgets, reporting on subawards, and monitoring 

subrecipients. Selected administrative requirements in agency-specific 

guidance generally focus on promoting the quality and effectiveness of 

federally funded research. These include requirements related to 

developing and submitting biographical sketches; mentoring and 

developing researchers; identifying, reporting, and managing financial 

conflicts of interest; and managing and sharing research data and results.

OMB developed the Uniform Guidance to (1) streamline OMB’s guidance 

for federal awards to ease administrative burden and (2) strengthen 

oversight of federal funds to reduce risks of waste, fraud, and abuse.14

OMB developed the Uniform Guidance over more than 2 years, and it 

reflects input from federal agencies, auditors, and recipients of federal 

awards, which OMB solicited in an effort to balance its dual goals of 

streamlining and accountability. The Uniform Guidance includes 

provisions related to a range of administrative requirements on research 

grants, including ones we selected related to competing and documenting 

purchases, documenting personnel expenses, preparing and managing 

project budgets, subaward reporting, and subrecipient monitoring. OMB 

 1378 Fed. Reg. 78,590 (Dec. 26, 2013). 

1478 Fed. Reg. 78,590 (Dec. 26, 2013).

OMB’s GovernmentWide Requirements 

Generally Govern the 

Proper Use of Grant 

Funds, and AgencySpecific 

Requirements 

Generally Govern 

Research Quality and 

Effectiveness

Selected Administrative 

Requirements in OMB’s 

Government-Wide Grant 

Guidance Generally Focus 

on Protecting against 

Waste, Fraud, and Abuse 

of Funds
Page 13 GAO-16-573 Federal Research Grants

required each individual funding agency to implement the Uniform 

Guidance by adopting regulations that apply to the agency’s awards.15

See appendix II for additional information on selected requirements in the 

Uniform Guidance.

The requirements in the Uniform Guidance aim to protect against waste, 

fraud, and abuse in various ways, as follows.

• Budgets. Funding agencies implement Uniform Guidance 

requirements for budget preparation and management by designing 

forms and processes to review applicants’ requests for funding, and

grantees’ use of funding, to determine, among other things, whether 

costs are allowable. These requirements allow for identification of 

questionable requests for funding in applications or unallowable postaward charges to grants.

• Personnel expenses. To document personnel expenses, grantees 

must maintain a system of internal controls over their records used to 

justify the costs of salaries and wages so these records accurately 

reflect the work performed. Salary and wage costs generally represent 

the largest portion of expenditures on research grants according to 

agency officials, and NSF and HHS offices of inspector general have 

reported on the need for oversight to prevent improper or fraudulent 

salary charges. For example, the NSF Office of Inspector General has 

documented instances of researchers charging their full-time salaries 

to federal grants at one university while simultaneously working fulltime at another university or for-profit company.

• Purchases. To meet documentation requirements for purchases 

made with grant funds, grantees must maintain records detailing the 

procurement history for all purchases.16 Funding agencies and their 

inspectors general use such purchasing records for oversight, 

including detection and prosecution of fraudulent purchases. Audit 

reports by the NSF and HHS offices of inspector general have found 

 15OMB allowed funding agencies some flexibility in their implementation of the guidance 

by permitting agencies to seek OMB approval for exceptions to certain requirements 

under certain circumstances.

16Specifically, the Uniform Guidance requires recipients to maintain records including, but 

not limited to, the rationale for the method of procurement, selection of contract type, 

contractor selection or rejection, and the basis for the contract price.
Page 14 GAO-16-573 Federal Research Grants

instances of researchers using grant funds for personal purchases. In 

addition, the Uniform Guidance requires that purchases be conducted 

in a manner providing full and open competition, and establishes five 

methods for purchasing goods or services. These methods include 

obtaining price or rate quotations, competitive bids, or competitive 

proposals for certain purchases.

• Subrecipients. Universities frequently collaborate with and provide 

federal research funds to other institutions, domestic and foreign, 

through subawards. Awarding agencies rely on grantees to monitor 

subrecipients to ensure that they use research funds for authorized 

purposes and stay on track to meet performance goals. In addition, 

requirements for grantees to report on their subawards provide 

agencies, Congress, and the public more information on 

subrecipients' use of taxpayer dollars.

Funding agencies have established administrative requirements—in 

some cases, in response to directives from Congress and OSTP—to 

promote the selection and development of qualified researchers, protect 

against bias in the conduct of research, and improve access to research 

results. Agencies implement these requirements through their grants 

guidance documents and the terms and conditions of their awards. See 

appendix II for additional information on selected agency-specific 

requirements.

• Promoting the selection and development of qualified 

researchers. Funding agencies require applicants to submit 

biographical sketches so the agencies have information they need to 

select well-qualified researchers. All four funding agencies in our 

review have agency-specific requirements for biographical sketches in 

their grants guidance, including requirements for applicants to list 

information about past publications and current and prior academic or 

professional positions. Also, to promote the professional development 

of researchers, two of the four agencies have requirements related to 

researcher development or mentoring plans. First, as directed in the 

America Creating Opportunities to Meaningfully Promote Excellence 

in Technology, Education, and Science Act of 2007, NSF requires that 

all proposals with postdoctoral researchers include a plan describing 

the mentoring to be provided to these researchers. Second, NIH 

encourages institutions to use individual development plans to identify 

and promote the career goals of graduate students and postdoctoral 

researchers associated with NIH awards, and requires grantees using 

Selected Administrative 

Requirements in AgencySpecific Guidance 

Generally Focus on 

Promoting the Quality and 

Effectiveness of Federally 

Funded Research
Page 15 GAO-16-573 Federal Research Grants

individual development plans to describe their use of these plans in 

annual progress reports.

• Protect against bias in the conduct of research. NASA, NIH, and 

NSF have implemented financial conflict of interest requirements to 

help protect against bias in the conduct of research, and DOE is in the 

process of establishing such requirements.17 For example, NIH and 

NSF require researchers to disclose and universities to review 

financial interests to identify potential conflicts, such as investments in 

or income from entities that might benefit from a research project. 

Since 1995, NIH-funded researchers have been subject to HHS 

financial conflict of interest regulations designed to promote 

objectivity.18 HHS revised its regulations in 2011 to address the 

growing size and complexity of biomedical and behavioral research 

and corresponding concerns about financial ties between researchers 

and industry—including pharmaceutical, medical device, and 

biotechnology companies. For example, congressional committee 

investigations had found cases of financial conflicts of interest that 

may have led to bias in NIH-funded research, including researchers 

failing to disclose substantial payments from drug and medical device 

companies. Similarly, in implementing its financial conflict of interest 

policy in 1994, NSF stated that it encourages the involvement of 

researchers and educators with industry and private entrepreneurial 

ventures but recognizes that these interactions are accompanied by 

an increased risk of conflicts of interest—a risk that its policy was 

intended to address.

 17The Uniform Guidance does not establish specific requirements for how grantees must 

identify and manage conflicts of interest, although it contains a general provision for 

agencies to establish policies that apply to conflicts that might arise around how recipients 

expend award funds, and a requirement that the grantee must maintain written standards 

of conduct covering conflicts of interest and governing the performance of its employees 

engaged in the selection, award and administration of contracts. 

18HHS’s financial conflict of interest regulation applies to institutions that receive funding 

from agencies in HHS’s Public Health Service, including NIH. Each recipient institution 

must maintain an up-to-date, written, enforced policy on financial conflicts of interest that 

complies with the regulation. For the purposes of this report, we focused on NIH’s 

implementation of the HHS financial conflict of interest regulation and did not review 

implementation by other Public Health Service agencies. The regulation defines an 

investigator as the person responsible for the design, conduct, or reporting of research 

funded by NIH and other Public Health Service agencies. For the purposes of this report, 

we use the term researcher instead of investigator.
Page 16 GAO-16-573 Federal Research Grants

• Improve access to research results. In 2013, OSTP directed federal 

agencies to support increased public access to the results of federally 

funded research, including results published in peer-reviewed journals 

as well as digital data.19 According to the OSTP directive, policies that 

provide greater access to peer-reviewed publications and scientific 

data maximize the impact and accountability of the federal research 

investment. In response to this directive, agencies established

requirements for researchers to develop and comply with data 

management plans that describe the scientific data to be collected 

and how the researcher will provide access to and reliable 

preservation of the data. All four funding agencies in our review 

require applicants to include data management plans in their 

proposals.20

Selected universities and stakeholder organizations identified common 

factors that add to their administrative workload and costs for complying 

with selected requirements: (1) variation in agencies’ implementation of 

requirements, (2) detailed pre-award requirements for applicants to 

develop and submit documentation for grant proposals, and (3) increased 

prescriptiveness of certain requirements.

At all six universities we selected for our review, officials told us that 

variation in funding agencies’ implementation of certain administrative 

requirements included in our review contributes to workload and costs. 

For example, they said variation contributes to universities’ costs because 

they have to design and implement multiple processes and may need to 

 19Director of the Office of Science and Technology Policy, Increasing Access to the 

Results of Federally Funded Scientific Research, Memorandum for the Heads of 

Executive Departments and Agencies from John P. Holdren, (Feb. 22, 2013). 

20If appropriate, researchers can explain in data management plans why they cannot 

justify long-term preservation of and access to scientific data. 

Selected Universities 

Identified Common 

Factors That Add to 

Their Workload and 

Costs for Complying 

with Selected 

Administrative 

Requirements

Variation in Funding 

Agencies’ Implementation 

of Administrative 

Requirements
Page 17 GAO-16-573 Federal Research Grants

invest in electronic systems to comply with agencies’ requirements, and it 

contributes to the workload of researchers and administrative staff 

because they must spend time learning the different requirements, 

processes, and systems.

Officials we interviewed from stakeholder organizations and the six 

universities cited variation in funding agencies’ implementation of three 

categories of requirements in particular as adding to administrative 

workload and costs: developing and submitting biographical sketches; 

identifying, reporting, and managing financial conflicts of interest; and 

preparing and managing project budgets. For example, the biographical 

sketches agencies require applicants to submit differ in formatting as well 

as in content, including the information applicants must provide on past 

publications, research collaborators, and academic positions. In addition, 

agencies’ financial conflict of interest requirements differ in the types of 

financial interests that researchers must disclose to their institutions, the 

information that institutions must report to agencies, and requirements for 

training researchers on conflicts of interest. Agency implementation of 

budget preparation and management requirements differs in several 

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

and the systems for grantee financial reporting. In 2014, the National 

Science Board reported that faculty and administrative staff participating 

in roundtable discussions and responding to its request for information 

cited a lack of consistency and standardization within and among 

agencies in all aspects of grant management—including regulations, 

guidance, reporting requirements, forms and formatting, and electronic 

systems—as a substantial source of administrative workload and costs, 

resulting in a loss of research time.21 Appendix III provides detailed 

examples of the differences in agencies’ implementation of selected 

requirements.

University officials we interviewed cited specific examples of increases in 

administrative workload and costs that resulted from variation in funding 

agencies’ implementation of requirements:

 21National Science Board, Reducing Investigators’ Administrative Workload for Federally 

Funded Research.
Page 18 GAO-16-573 Federal Research Grants

• Electronic systems costs. Universities have invested in electronic 

grant management systems for submitting grant applications and 

ensuring compliance with multiple agencies’ application requirements. 

Variations in requirements can make it more difficult for applicants to 

comply, and applications can be rejected for noncompliance, including 

noncompliance with formatting requirements such as page lengths or 

fonts. Universities’ systems help minimize such rejections by 

identifying noncompliant application elements prior to submission, 

according to university officials. To address variation between NIH’s 

and NSF’s conflict of interest requirements, five universities in our 

review updated their electronic systems, for example, to allow 

researchers and administrative staff to differentiate the types and 

thresholds for financial interests required to be disclosed by different 

agencies, according to university officials.

• Administrative staff workload and costs. Officials from the six 

universities in our review cited examples of investments in 

administrative staff that they made in part to address variation in 

agencies’ implementation of requirements. For example, according to 

officials we interviewed, four universities in our review employ specific 

administrative staff members with specialized expertise in the policies 

and procedures of particular agencies to review proposals and help 

ensure compliance with those agencies’ requirements. Universities’

administrative staff members may also in some cases manage 

proposal processes for multiple agencies, so the universities need to 

help them build and maintain expertise in the agencies’ various 

application systems and requirements, according to officials.

• Researcher workload. Officials at the six universities in our review 

said that researchers must spend time learning different agencies’

requirements and customizing and reformatting application materials 

for different agencies. For example, according to officials at the six 

universities, researchers spend time customizing the content, format, 

and length of biographical sketches to agency-specific requirements 

and learning how to comply with each agency’s policies on what 

information to include in proposed budgets.

Funding agencies require researchers to prepare detailed 

documentation—including proposed budgets, biographical sketches, 

information on subawards, data management plans, and in some cases 

information on conflicts of interest and researcher mentoring and 

development plans—and submit it to university administrators and 

agencies as part of the application process. Agencies require much of this 

information to help them select proposals for funding, according to 

Detailed Pre-Award 

Administrative 

Requirements
Page 19 GAO-16-573 Federal Research Grants

agency officials and guidance. According to university officials we 

interviewed, developing this documentation is time-consuming and adds 

to universities’ administrative workload and costs. Moreover, the 

likelihood of an agency selecting a proposal for funding is relatively low. 

For example, in fiscal year 2015, NIH awarded funding to 18 percent of 

applicants and NSF awarded funding to 24 percent of applicants—similar 

to funding rates from other years.22 As a result, for most grant proposals, 

universities’ investment of time and resources does not result in their 

receiving research funding.

According to officials from five of our selected universities, as well as 

reports from stakeholder organizations, pre-award requirements are one 

of the main sources of frustration and administrative workload and costs 

among researchers and administrative staff. The National Science Board 

reported in 2014 that faculty responding to its request for information cited 

the proposal and submission process, including preparing supporting 

documentation, as one of the grants management areas that contributed 

most to their administrative workload.23 For example, in response to the 

National Science Board’s request for information, the Federation of 

American Societies for Experimental Biology surveyed researchers, lab 

workers, and administrative staff and found that the respondents cited 

 22NSF data reflect the percentage of final proposals that resulted in awards—the data do 

not account for preliminary proposals, whereby an applicant submits a limited set of 

application materials and may be discouraged or barred from submitting a final proposal. 

As a result, the percentage of applicants receiving awards is somewhat lower than 

reflected by these data. 

23National Science Board, Reducing Investigators’ Administrative Workload for Federally 

Funded Research. The grants management area that respondents to the request for 

information most frequently cited as burdensome was financial management, which 

includes some pre-award activities such as budget preparation. The proposal and 

submission process was the second most frequently cited area of burden.
Page 20 GAO-16-573 Federal Research Grants

grant proposal preparation and submission as the greatest source of 

administrative burden out of 15 categories of burden in the survey.24

Researchers and administrative staff at the six universities in our review 

told us that during the pre-award stage, there can be a relatively high 

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

detailed budget information about potential vendors or travel costs, 

expected research data and results, and planned contributions by 

postdoctoral or graduate researchers. They said that complying with 

agencies’ requirements to prepare and submit documents at a stage 

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

Similarly, the Federation of American Societies for Experimental Biology 

reported that difficulty in accurately predicting detailed research budgets 

when submitting a proposal was specifically raised as a source of 

administrative burden in comments on its survey.

Recent OMB and HHS policy reforms have resulted in changes to 

selected requirements that have made them more prescriptive from the 

standpoint of universities and that, according to university officials, have 

added to their universities’ administrative workload and costs. 

Specifically, the Uniform Guidance—which was intended in part to better 

protect against waste, fraud, and abuse of grant funds—included revised 

requirements for competition and documentation of purchases that were 

more prescriptive than those in OMB’s prior circular that applied to 

universities.

25 In addition, in 2011, HHS revised regulations governing 

financial conflicts of interest—which apply to research funded by NIH and 

 24The Federation of American Societies for Experimental Biology, Findings of the FASEB 

Survey on Administrative Burden (June 7, 2013). The survey on administrative burden 

was distributed to the federation’s 26 member societies, which collectively represent over 

115,000 biological and biomedical researchers, as well as through the listservs of other 

professional societies, universities, and research coalitions. The survey was completed by 

1,324 respondents. The report did not specify how many individuals received the survey 

or what the overall response rate was. The results of the survey were included in the 

National Science Board’s results.

25Stakeholder organizations raised concerns to OMB about increased administrative 

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

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

Uniform Guidance. The revised purchasing requirements will become effective for 

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

Administrative 

Requirements That Have 

Become More Prescriptive
Page 21 GAO-16-573 Federal Research Grants

several other HHS agencies—to address concerns about the objectivity of 

the research it funds. These revisions included more prescriptive 

requirements for, among other things, the types of financial interests 

researchers must disclose. See table 2 for requirements that have 

become more prescriptive under recent reforms.

Table 2: Selected OMB and HHS Requirements That Have Become More Prescriptive

Requirement category Prior version Current version 

Competition and 

documentation of

purchases

Office of Management and Budget (OMB) 

Circular No. A-110 required grantees to maintain 

documentation of some form of cost or price 

analysis for all purchases.

For purchases in excess of the small purchase 

threshold ($25,000 when OMB issued the 

circular), grantees were also required to maintain 

documentation on the basis for contractor 

selection; justification for lack of competition 

when competitive bids or offers were not 

obtained; and basis for award cost or price.

The Uniform Administrative Requirements, Cost 

Principles, and Audit Requirements for Federal Awards

(Uniform Guidance) requires grantees to maintain records 

sufficient to detail the history of procurement for all 

purchases. Such documentation must include, but is not 

limited to, rationale for the method of procurement, 

selection of contract type, contractor selection or 

rejection, and the basis for the contract price.

For purchases above the micropurchase threshold 

($3,000 when OMB issued the Uniform Guidance), 

grantees must generally obtain price or rate quotations, 

competitive bids, or competitive proposals. Price and rate 

quotations and competitive bids must be from an 

adequate number of qualified sources.a

Financial conflict of 

interest (Department of 

Health and Human 

Services)b

The Department of Health and Human Services’

(HHS) 1995 regulations governing financial 

conflicts of interest included the following 

requirements:

• Financial interests of $10,000 or more that 

would reasonably appear to be affected by 

the research for which funding is sought 

must generally be disclosed.

• Researchers do not need to disclose income 

from any nonprofit entities for activities such 

as seminars, lectures, or teaching.

• The regulation does not specifically address 

occurrences of reimbursed or sponsored 

travel.

HHS’s 2011 regulations governing financial conflicts of 

interest include the following requirements:

• Financial interests of $5,000 or more that are related 

to the researcher’s institutional responsibilities must 

generally be disclosed.c

• Researchers do not need to disclose income from 

some nonprofit entities, such as universities and 

teaching hospitals, for activities such as seminars, 

lectures, or teaching.

• The regulation requires disclosure of occurrences of 

reimbursed or sponsored travel related to institutional 

responsibilities, including the purpose, sponsor, 

destination, and duration of trips.

• The regulation includes additional requirements for 

institutions to train researchers on conflict of interest 

issues in certain circumstances, including when the 

researcher is new to the institution; make public any 

identified financial conflicts of interest held by 

senior/key personnel; and retrospectively review the 

researcher's activities and the research project 

whenever a financial conflict of interest is not 

identified or managed in a timely manner to 

determine whether any research conducted during 

the period of noncompliance was biased in its 

design, conduct, or reporting.

Source: GAO analysis of OMB and HHS requirements. | GAO-16-573
Page 22 GAO-16-573 Federal Research Grants

a

OMB delayed implementation of the Uniform Guidance procurement standards for 2 full fiscal years 

after the effective date of the Uniform Guidance. The revised standards will become effective for 

universities sometime in 2017, depending on universities’ fiscal calendars. The Uniform Guidance 

defines the micropurchase threshold as the threshold set by the Federal Acquisition Regulation at 48 

C.F.R. Subpart 2.1 (Definitions). It is $3,000 except as otherwise discussed in Subpart 2.1 of that 

regulation, but this threshold is periodically adjusted for inflation. See 2 C.F.R. § 200.67. At the time 

of our report, the threshold was $3,500. The Uniform Guidance provides an exception to competition 

of purchases above the threshold in limited cases, such as purchases of items that are only available 

from a single source.

b

HHS’s financial conflict of interest regulation applies to institutions that receive funding from agencies 

in HHS’s Public Health Service, including NIH. Each recipient institution must maintain an up-to-date, 

written, enforced policy on financial conflicts of interest that complies with the regulation. The 

regulation defines an investigator as the person responsible for the design, conduct, or reporting of 

research funded by NIH and other Public Health Service agencies. For the purposes of this report, we 

use the term researcher instead of investigator.

c

HHS defines institutional responsibilities as researchers’ professional responsibilities on behalf of 

their institution, and as defined by an institution in its policy on financial conflicts of interest, which 

may include activities such as research, research consultation, teaching, professional practice, 

institutional committee memberships, and service on panels such as institutional review boards or 

data and safety monitoring boards.

Officials at universities in our review stated that the more prescriptive 

requirements add to universities’ workload and costs when, for example, 

new or updated systems and processes must be implemented. Officials 

cited the following examples of needing to implement new or updated 

systems and processes to comply with the more prescriptive 

requirements:

• Officials at all six universities told us that they expect the new 

purchasing competition and documentation requirements—particularly 

the new micropurchase threshold for obtaining price or rate quotations 

from multiple vendors—will result in added costs for updating their 

electronic purchasing systems.26 For example, prior to the Uniform 

 26The Uniform Guidance requires that all procurement transactions be conducted in a 

manner providing full and open competition, and establishes five methods for purchasing 

goods or services: (1) procurement by micropurchases, which applies to purchases under 

the micropurchase threshold and does not require soliciting competitive quotations if the 

grantee considers the price to be reasonable; (2) procurement by small purchases, which 

are methods for purchases that do not cost more than the simplified acquisition 

threshold—currently set at $150,000—and for which grantees must obtain price or rate 

quotations from an adequate number of qualified sources; (3) procurement by sealed bids, 

for which grantees must publicly solicit bids and award a firm fixed price contract to the 

responsible bidder whose bid is the lowest in price; (4) procurement by competitive 

proposals, which is normally conducted with more than one source submitting an offer; 

and (5) procurement by noncompetitive proposals, which the Uniform Guidance allows in 

limited cases, such as for items that are only available from a single source. 
Page 23 GAO-16-573 Federal Research Grants

Guidance, five of the universities in our review told us that they had 

established a higher threshold than the Uniform Guidance for 

obtaining multiple quotations, and that there will be a large increase in 

the number of transactions exceeding the new threshold. The grantee 

community raised concerns to OMB about not being adequately 

prepared to comply with the more prescriptive purchasing 

requirements, and OMB delayed implementation of the purchasing 

requirements for 2 years.

• Five of the universities in our review developed and implemented a 

new electronic system to comply with NIH’s revised conflict of interest 

requirements, according to university officials. Similarly, officials from 

the Association of American Medical Colleges who are studying the 

effect of NIH’s conflict of interest requirements told us that institutions 

have reported incurring costs to implement processes and systems, 

such as financial interest-tracking software, to comply with the new 

requirements.27

Universities have had to hire and train staff to comply with more 

prescriptive requirements, according to officials at the six universities in 

our review. Officials at four universities said they expect to hire staff to 

handle the added workload resulting from an increased volume of 

purchases subject to OMB’s revised purchasing competition and 

documentation requirements. In addition, officials from all six universities 

said that they provided additional training to researchers on NIH’s conflict 

of interest requirements—as required by the revised rule—and officials 

from three universities said that each university hired an additional

administrative staff member to manage the overall process for reviewing 

and reporting on financial conflicts of interest.

In contrast with its revised purchasing requirements, OMB largely 

maintained existing subrecipient monitoring requirements in the Uniform 

Guidance. Nevertheless, according to officials from universities and 

stakeholder organizations we interviewed, the prescriptive nature of the 

subrecipient monitoring requirements adds to universities’ administrative 

 27The Association of American Medical Colleges, in coordination with NIH, is conducting a 

review to understand the effect of the revised NIH conflict of interest requirements by 

comparing institutions’ resources needed to comply with the requirements in the year prior 

to the revisions, with the resources needed for compliance in the years following the 

revisions. 
Page 24 GAO-16-573 Federal Research Grants

workload and costs. Under these requirements, grantees have the 

flexibility to conduct some monitoring activities, such as on-site reviews or 

subrecipient training, as they determine appropriate based on their 

assessment of a subrecipient’s risk of misusing grant funds. However, the 

Uniform Guidance requires grantees to (1) follow-up and ensure that 

every subrecipient, regardless of risk, take timely and appropriate action 

on all deficiencies pertaining to the subaward detected through audits, onsite reviews, and other means, and (2) issue management decisions for 

such deficiencies. University officials we interviewed said that to meet 

these requirements, they may have to review audits of hundreds of 

subrecipients each year, including lengthy audits of state governments for 

subawards provided to public universities. Officials from universities and 

stakeholder groups we interviewed said that much of the administrative 

workload and costs for complying with the audit review and follow-up 

requirements is unnecessary, particularly for low-risk subrecipients such 

as those with histories of successfully conducting federally funded 

research.

In some cases—particularly for universities subject to state 

requirements—the revised requirements did not substantially add to 

universities’ administrative workload and costs. The three public 

universities in our review have had to comply with state requirements 

related to purchasing or conflicts of interest that were already more 

stringent than federal requirements in some ways. For example, officials 

at one public university told us that the university was well-positioned to 

comply with NIH’s conflict of interest requirements because it already had 

processes in place to comply with more stringent state conflict of interest 

requirements.

Agency officials said that some of universities’ administrative workload 

and costs may be due to their interpretations of requirements that are 

stricter than agencies intended. For example, OMB staff said grantees do 

not have to review audits of subrecipients’ full financial statements and 

internal controls systems, since the Uniform Guidance requires grantees 

to follow up and issue management decisions only for audit findings that 

are related to their subaward. However, officials from universities and 

stakeholder groups said that universities are concerned that they need to 

interpret and comply with requirements to the standards they believe 

agency inspectors general may apply in an audit. These officials cited 

recent audit reports by the HHS and NSF offices of inspector general that 

found universities had charged unallowable or questionable costs to 

research grants. Some of these audit findings stemmed from differences 

in how auditors, agencies and universities interpreted requirements.
Page 25 GAO-16-573 Federal Research Grants

OMB and the four research funding agencies in our review have made 

continuing efforts to reduce universities’ administrative workload and 

costs for complying with selected requirements. These efforts have 

included (1) standardizing requirements across agencies, (2) streamlining 

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

more flexibility to assess and manage risks for some requirements. In 

each of these areas, OMB and agency efforts have resulted in some 

reductions to administrative workload and costs, but these reductions 

have been limited.

OMB and funding agencies have made several efforts to reduce grantees’

administrative workload and costs by standardizing selected 

requirements, in accordance with federal goals, and several of these 

efforts are ongoing. The Federal Financial Assistance Management 

Improvement Act of 1999 was enacted in part to improve the 

effectiveness and performance of federal financial assistance programs 

and facilitate greater coordination among those responsible for providing 

such assistance. For example, the act, which expired in 2007, required 

agencies to establish a common application reporting system, including 

uniform administrative rules for federal financial assistance programs. 

More recently, Executive Order 13563 called for agencies to coordinate 

and harmonize regulations to reduce compliance costs. In addition, in 

2003 OSTP established the Research Business Models working group 

(RBM)—which consists of officials from DOE, NASA, NIH, NSF, and other 

federal research funding agencies—to facilitate coordination across these 

agencies.28 RBM’s charter calls for it to examine opportunities and 

develop options to unify agency research grants administration practices, 

and to assess and report periodically on the status, efficiency, and 

performance of the federal-academic research partnership.

 28RBM is an interagency working group within the National Science and Technology 

Council. This council, within OSTP, is the executive branch’s principal means for 

coordinating science and technology policy across the entities that make up the federal 

research and development enterprise.

OMB and Funding 

Agencies Have Made 

Continuing Efforts to 

Reduce Universities’

Administrative 

Workload and Costs, 

with Limited Results

OMB and Funding Agency 

Efforts to Standardize 

Some Administrative 

Requirements Have Not 

Fully Addressed Variations
Page 26 GAO-16-573 Federal Research Grants

In accordance with such federal goals, OMB-led efforts to standardize 

selected requirements—particularly requirements for budget preparation 

and management—include the following:

• Grants.gov. In 2003, OMB created Grants.gov—a common website 

for federal agencies to post discretionary funding opportunities and for 

grantees to find and apply for them.29 Intended in part to simplify the 

grant application process and save applicants costs and time, 

Grants.gov allows for standard government-wide submission 

processes and forms for research grants.

• Standardization of financial and performance reporting forms. As 

discussed previously, in December 2013, OMB consolidated its grants 

management guidance into a single document, the Uniform Guidance, 

which established standard requirements for financial management of 

federal awards across the federal government. In particular, it 

generally requires the use of OMB-approved government-wide 

standard forms for reporting financial and performance information.

• Digital Accountability and Transparency Act pilot program. The 

Digital Accountability and Transparency Act of 2014 requires OMB to 

establish a pilot program to identify ways to standardize financial and 

other information that recipients of federal awards are required to 

report to agencies across the government, among other things.30 This 

pilot is ongoing and includes testing approaches to (1) allow grant 

recipients to submit financial reports in one central system and (2) 

develop consistent government-wide financial and other terms and 

definitions to simplify recipient reporting and help agencies create 

information collection forms.31

 29The Federal Financial Assistance Management Improvement Act of 1999, commonly 

referred to by the grants community as P.L. 106-107, required OMB to direct, coordinate, 

and assist agencies in developing and implementing a common application and reporting 

system for grants. 

30Pub. L. No. 113-101, 128 Stat. 1146 (May 9, 2014).

31We reported in April 2016 that the portion of the Digital Accountability and Transparency 

Act pilot program focused on reducing grantee reporting burden is generally on track to 

meet the requirements of the act. GAO, Data Act: Section 5 Pilot Design Issues Need to 

Be Addressed to Meet Goal of Reducing Recipient Reporting Burden, GAO-16-438 

(Washington, D.C.: Apr. 19, 2016)
Page 27 GAO-16-573 Federal Research Grants

In addition, research funding agencies have led several efforts through 

RBM to standardize selected requirements, including the following:

• Federal research terms and conditions. In 2008, RBM developed a 

standard core set of administrative terms and conditions for research 

grants, which implemented OMB’s grants management guidance in 

effect at that time. The research terms and conditions included 

standard provisions related to some selected post-award 

requirements, such as budget management and financial reporting. In 

2014, RBM began a process to develop a revised set of standard 

terms and conditions to apply to research grants subject to OMB’s 

revised requirements under the Uniform Guidance. Agency officials 

said they estimate that the revised standard terms and conditions will 

be issued in late 2016 or early 2017.32

• Research Performance Progress Report. In 2010, RBM issued, and 

OSTP and OMB directed agencies to implement, the Research 

Performance Progress Report, a uniform format for post-award 

performance reporting for federally funded research projects. The 

report is intended to reduce recipients’ administrative workload by 

standardizing the types of information required in interim performance 

reports, such as budget information. In 2015, RBM drafted a revised 

version of the Research Performance Progress Report, which is to be 

used for both interim and final reports.

• SciENcv. In 2013, research funding agencies worked under RBM’s 

direction to develop SciENcv, a central electronic portal where 

researchers can assemble biographical information, intended to 

reduce the administrative workload and costs associated with creating 

and maintaining federal biographical sketches. Initially designed for 

NIH applications, SciENcv is currently being expanded to allow 

researchers to generate and maintain biographical sketches for 

multiple agencies, including NSF, in the formats required by those 

agencies.

 32Agencies are using agency-specific research terms and conditions to apply to awards 

made after the Uniform Guidance became effective in December 2014 and until the 

revised set of standard research terms and conditions are issued. An official leading the 

development of the standard research terms and conditions said that because there are 

multiple committees and federal agencies involved in reviewing and approving the terms 

and conditions, it is not certain when exactly they will be finalized and implemented by 

agencies.
Page 28 GAO-16-573 Federal Research Grants

See appendix IV for more information on OMB and funding agency efforts 

to standardize selected administrative requirements.

However, OMB’s efforts to standardize requirements did not fully address 

the variations in requirements, thereby limiting the potential reductions in 

universities’ administrative workload and costs. For example, the Uniform 

Guidance does not prohibit agencies from varying in their implementation 

of aspects of budget preparation and management requirements. 

Specifically, as previously discussed, the four funding agencies in our 

review vary in the forms and level of detail required in proposed budgets, 

their systems for financial reporting, and other aspects of budget 

preparation and management requirements.

Similarly, research funding agency and OSTP efforts have not fully 

addressed variation in requirements. For example, (1) RBM has not 

initiated a process to standardize pre-award requirements (its standard 

terms and conditions and Research Performance Progress Report both 

focus on post-award requirements); (2) SciENcv provides a central 

system for assembling biographical sketches, but it does not provide 

standardized formats and content and it has not been adopted outside of 

NIH and NSF; and (3) RBM’s efforts to standardize research terms and 

conditions, both prior to and following the issuance of the Uniform 

Guidance, allow for agency-specific variations. For example, according to 

officials drafting the revised research terms and conditions, RBM 

considered establishing a standard 120-day deadline for institutions to 

submit final reports required for closing out grants—an increase over the 

90-day deadline some agencies had previously established. However, the 

officials said that some agencies indicated they would not increase their 

closeout deadlines beyond 90 days. The officials said that to gain these 

agencies’ agreement to use the standard terms and conditions, the terms 

and conditions will allow deviations from the standard closeout time 

frames.

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

limit agencies’ ability to standardize administrative requirements on 

research grants. First, funding agencies must comply with differing 

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

requirements for grantees. For example, NIH must comply with HHS’s 

regulations on conflict of interest requirements and is limited in how it can 
Page 29 GAO-16-573 Federal Research Grants

change its conflict of interest requirements to align with those of other 

agencies without HHS amending its regulations.33 Second, there are 

differences in the types of research or recipients agencies fund that can 

limit their ability to standardize requirements. For example, the types of 

data that research projects generate, and the constraints on sharing such 

data, can vary depending on the type of research universities are 

conducting. Researchers may not be able to share personally identifiable 

medical data as they would other types of data, for instance. These 

differences can limit agencies’ ability to standardize requirements related 

to data management and sharing, according to agency officials.

Nevertheless, agencies have opportunities to standardize requirements to 

a greater extent than they have already done. In particular, they have 

flexibility in how they implement certain aspects of selected requirements 

that are not subject to statutory or other requirements or to agencyspecific differences in types of research or grant recipients. According to 

some funding agency officials we interviewed, aspects of requirements 

where agencies have such flexibility include, for example, the format and 

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

justifications that agencies require in applications, and the types of budget 

revisions agencies allow grantees to make without obtaining prior 

approval. Officials at NSF, NIH, and OSTP who co-chair RBM told us that 

the group has been fully occupied with ongoing efforts related to 

developing standard research terms and conditions and the Research 

Performance Progress Report. RBM officials leading these efforts said 

that they expect them to be complete in late 2016 or early 2017, and that 

RBM is well suited to pursue further efforts to standardize requirements 

and to report on its efforts. Such efforts could help ensure that agencies 

do not miss opportunities to reduce universities’ administrative workload 

and costs and to improve their oversight of funding and support of 

research quality.

 33A bill pending in the Senate (S. 2742) would, among other things, require the Secretary 

of Health and Human Services to harmonize existing conflict of interest policies and 

reduce administrative burden on researchers while maintaining the integrity and credibility 

of research findings. S. 2742, § 3(a)(1)(B).
Page 30 GAO-16-573 Federal Research Grants

DOE, NASA, NIH, and NSF have made efforts to reduce pre-award 

administrative workload and costs associated with proposal preparation 

by postponing certain requirements until after a preliminary decision 

about an applicant’s likelihood of funding.34 These efforts require 

applicants to provide a limited set of application materials—often referred 

to as a preliminary proposal—for initial evaluation before possible 

submission of a full proposal. Preliminary proposals are intended, in part, 

to reduce applicants’ administrative workload and costs when applicants’

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

charter, which calls for agencies to identify approaches to streamline 

research grants administration practices. Furthermore, several 

organizations representing federal agencies and university researchers, 

including the National Science Board and Federation of American 

Societies for Experimental Biology, have recommended such efforts to 

streamline proposal processes. For example, according to findings from 

the National Science Board’s request for information, respondents 

suggested that much of the information agencies required at proposal 

submission may not be necessary, and the board recommended that 

agencies modify proposal requirements to include only information 

needed to evaluate the merit of the proposed research and make a 

funding determination.35

The funding agencies in our review implement a range of preliminary 

proposal processes, which can involve postponing requirements related 

to budget preparation, biographical sketches, data management plans, 

and researcher mentoring and development plans. For example, NSF’s 

preliminary proposals generally include a four-page project description 

and a one-page description of project personnel, among other elements, 

but may not include budgets, budget justifications, data management 

plans, or postdoctoral mentoring plans. NIH’s “just–in-time” process 

 34In addition to agency efforts to postpone pre-award requirements until preliminary 

decisions about the likelihood of funding have been made, agencies have made efforts to

reduce pre-award administrative workload and costs by streamlining application 

instructions and formatting or through the use of electronic application portals and other 

information technology systems. For example, NIH has an ongoing effort to enhance and

streamline its processes for peer reviews of applications by, for example, shortening page 

limits and aligning application elements with review criteria.

35National Science Board, Reducing Investigators’ Administrative Workload for Federally 

Funded Research.

Funding Agency Efforts to 

Reduce Pre-Award 

Administrative Workload 

and Costs by Postponing 

Proposal Requirements 

Have Not Been Extended 

to All Applicable Grants or 

Requirements
Page 31 GAO-16-573 Federal Research Grants

allows some elements of an application to be submitted after the 

application has gone through initial peer review and received a qualifying 

score from the peer review panel. For example, certain data management 

plans can be submitted at the just-in-time stage, but other information, 

such as budgets and biographical sketches, must generally be submitted 

with the initial application. In some cases, agencies use peer reviewers to 

evaluate preliminary proposals and make binding decisions as to whether 

applicants can submit full proposals. In other cases, agency program 

officers evaluate preliminary proposals and provide feedback either 

discouraging or encouraging applicants to submit full proposals. See 

appendix IV for more information on funding agency efforts to streamline 

selected pre-award administrative requirements through preliminary 

proposals.

According to university officials, stakeholder organizations, and 

information from the four funding agencies in our review, efforts to 

postpone the timing of certain pre-award requirements have generally led 

to reductions in universities’ administrative workload and costs. For 

example, one NSF division evaluated its preliminary proposal pilot in 

2014, and reported that the pilot led to reduced applicant workload by 

lessening the number of proposal pages researchers needed to write and 

simplifying the documents university administrative offices required of 

applicants, since preliminary proposals do not include budgets. According 

to NSF data, NSF received approximately 4,900 preliminary proposals in 

fiscal year 2014 and discouraged or barred applicants from submitting full 

proposals for more than 3,700 of them. As a result, those applicants 

avoided the administrative workload and costs of preparing full budgets 

and other documentation for proposals that would not be funded. Officials 

from the six universities in our review said that application processes that 

allow researchers to focus more of their pre-award time developing and 

describing the scientific and technical aspects of the proposed research 

were a more efficient use of their time than developing detailed budgets 

or other information that agencies may not need to make an initial funding 

decision and that may change by the time the research is conducted. For 

example, as noted above, staff at the six universities told us that budget 

details such as potential vendors or travel costs, or other details such as 

expected research data and results or planned contributions by 

postdoctoral researchers, are often not known with certainty at the preaward stage. Similarly, according to findings from the National Science 

Board’s request for information, respondents suggested that the 

administrative workload of both applicants and reviewers can be 

substantially reduced through use of preliminary proposals and other 

approaches for postponing submission of information.
Page 32 GAO-16-573 Federal Research Grants

However, agencies have not extended these pre-award streamlining 

efforts to all grant solicitations for which they could be used to reduce 

workload and costs. In addition, for certain requirements, agencies still 

require documentation that they may not need to effectively evaluate 

initial proposals. For instance, NIH’s just-in-time process does not 

generally postpone requirements for proposed budgets, disclosure of 

significant financial interests, or biographical sketches, among others—

requirements that other agencies have determined are not necessary for 

preliminary proposals. In addition, pre-award streamlining efforts at DOE, 

NASA, and NSF are limited to certain offices or certain programs within 

the agencies, in some cases because the efforts are still in pilot phases. 

Partly in response to the National Science Board’s 2014 

recommendations to reduce administrative workload by expanding the 

use of preliminary proposals or just-in-time submissions,36 NSF took 

steps to identify opportunities for expanding pre-award streamlining 

efforts agency-wide. Specifically, in 2015, NSF senior leadership directed 

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

researchers’ administrative workload and costs, including by expanding 

use of preliminary proposals and by focusing application reviews on a 

minimum set of elements that are needed to meet NSF’s two merit review 

criteria: (1) intellectual merit and (2) broader impact, which encompasses 

the potential benefit to society. As a result of the directive, three NSF 

directorates expanded their use of preliminary proposals, for instance, by 

piloting efforts to postpone requirements to submit detailed budgets until 

proposals are recommended for award. DOE, NASA, and NIH have not 

conducted similar agency-wide reviews to identify opportunities for 

reducing administrative workload and costs by expanding their use of 

preliminary proposals or just-in-time submissions, according to agency 

officials.37 Such reviews may help ensure that agencies do not miss 

 36National Science Board, Reducing Investigators’ Administrative Workload for Federally 

Funded Research. 

37In commenting on a draft of our report, HHS stated that in 2014, NIH commissioned an 

evaluation to recommend ways to further optimize the process of reviewing, awarding, and 

managing grants and to maximize the time researchers can devote to research. The 

resulting report also found that the use of preliminary proposals could be expanded and 

included a recommendation that NIH pilot test preliminary proposals. NIH, Scientific 

Management Review Board, Report on Streamlining the NIH Grant Review, Award, and 

Management Process (July 2015). 
Page 33 GAO-16-573 Federal Research Grants

opportunities to reduce unnecessary pre-award administrative workload 

and costs for applicants that do not receive awards.

According to funding agency officials we interviewed, preliminary 

proposals may not be effective in reducing administrative workload and 

costs for certain solicitations or certain research grant programs. For 

example, DOE officials said they do not use preliminary proposals for 

certain specialized grant programs in fields with a small number of 

scientists who are likely to apply. Similarly, NSF officials said that 

preliminary proposals can create additional workload and costs for 

solicitations where the large majority of applicants go on to submit full 

proposals. Officials from DOE and NASA also said that researchers value 

the opportunity for peer review and feedback on their full proposals 

because it helps them improve their future applications. In addition, 

agency regulations may establish time frames that prevent postponing 

certain requirements until a smaller pool of likely awardees has been 

identified. For instance, under HHS regulations governing NIH’s financial 

conflict of interest requirements, researchers who have not previously 

disclosed their significant financial interests must do so no later than the 

time of application for NIH funds.38 However, Executive Order 13563 

directs agencies to identify and consider regulatory approaches that 

reduce burdens and maintain flexibility. For research grant requirements, 

such approaches could include modifying regulations to allow for 

postponing pre-award requirements. Coordinating and reporting on 

opportunities agencies have identified for expanded use of preliminary 

proposals would be in line with RBM’s charter.

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

goals, to reduce administrative workload and costs by allowing 

universities more flexibility to assess and manage risks related to certain 

administrative requirements. Executive Order 13563 calls for agencies to 

identify and consider regulatory approaches that reduce burdens and 

maintain flexibility for the public. Accordingly, one of OMB’s stated 

objectives for its reforms in the Uniform Guidance was “focusing on 

performance over compliance for accountability.” For example, in its 

statements in the Federal Register accompanying the final Uniform 

 3842 C.F.R. § 50.604(e)(1).

OMB and Funding Agency 

Efforts to Allow More

Flexibility Have Not 

Addressed Some 

Requirements
Page 34 GAO-16-573 Federal Research Grants

Guidance, OMB reiterated its commitment to allow recipients of federal 

awards the flexibility to devote more effort to achieving programmatic 

objectives rather than complying with complex requirements, such as by 

reforming requirements that are overly burdensome. Efforts by OMB and 

the funding agencies in our review to allow universities more flexibility to 

assess and manage risks related to administrative requirements—

particularly requirements for budget preparation and management and 

documentation of personnel expenses—include the following:

• Expanded authorities. OMB revised its grants guidance in the 1990s 

to allow “expanded authorities” for grant recipients. The expanded 

authorities allowed funding agencies to waive requirements for 

recipients to obtain agencies’ prior written approval before making 

certain changes to project budgets, such as rebudgeting funds across 

budget categories and carrying forward unobligated balances to later 

funding periods. Under RBM’s 2008 standard terms and conditions 

that implemented that guidance, DOE, NASA, NIH, and NSF waived 

many requirements for recipients to obtain prior approvals for budget 

revisions. Agency officials said that since the issuance of the Uniform 

Guidance they are continuing many of these waivers.

• Revised requirements for documenting personnel expenses. In 

the Uniform Guidance, OMB modified requirements for documenting 

personnel expenses to focus on establishing standards for recipients’

internal controls over salary and wage expenses, without prescribing 

procedures grantees must use to meet the standards. OMB expected 

this change to reduce grantees’ administrative workload and costs by 

allowing them the flexibility to use internal controls that fit their needs. 

In 2011, prior to the Uniform Guidance, four universities, in 

coordination with the Federal Demonstration Partnership and 

research funding agencies, began piloting a new method for 

documenting salary and wage charges to federal awards, known as 
Page 35 GAO-16-573 Federal Research Grants

payroll certification.39 OMB and the offices of inspector general at 

NSF and HHS agreed that the pilot would include subsequent audits 

by the offices of inspector general in order to evaluate the results.

• Modular budgets. In 1999, NIH implemented modular budgets, which 

generally apply to all NIH research grant applications requesting up to 

$250,000 per year. NIH allows recipients to request budgets in 

$25,000 increments—or “modules”—and decide after receiving an 

award whether to establish detailed budgets or to continue budgeting 

in $25,000 increments. In addition, under modular budgets, NIH 

allows applicants to provide more limited narratives to support certain 

budget line items than they would provide under non-modular 

budgets.

See appendix IV for more information on OMB and funding agency efforts 

to allow flexibility for grantees related to selected administrative 

requirements.

OMB’s and funding agencies’ efforts to allow universities more flexibility 

have led to reductions in administrative workload and costs. For instance, 

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

generally agreed that OMB’s expanded authorities reduced grantees’

administrative workload and costs associated with post-award budget 

revisions. In addition, officials from both universities in our review that 

piloted a payroll certification system said that it resulted in over an 80 

percent reduction in the number of forms that principal investigators 

needed to review and corresponding reductions in time needed to 

develop and process these forms. Officials from both universities also 

said the time and costs of training staff were lower under the pilot, 

because fewer people were responsible for certifying payroll reports than 

 39The Federal Demonstration Partnership proposed and initiated this pilot. Prior to the 

pilot, the four universities employed the widespread practice of using effort reports as the 

main support for salary and wage charges to federal grants and contracts. Effort reporting 

is a person-based methodology that allocates each individual’s salary to the various 

projects he or she worked on during the reporting period. In contrast, payroll certification is 

a project-based methodology that relies on a project’s principal investigator to certify that 

all salaries charged to the project are fair and reasonable in relation to the work 

performed. The Federal Demonstration Partnership asserted that payroll certification is 

preferable to effort reporting because (1) effort is difficult to measure and therefore effort 

reports provide limited internal control and (2) effort reporting systems can be expensive 

to implement and maintain.
Page 36 GAO-16-573 Federal Research Grants

had been responsible for certifying effort reports, and the concept of 

payroll certification is easier to understand than effort reporting. 

Furthermore, agency inspector general audits of two of the universities 

participating in the pilot found that the universities’ implementation of 

payroll certification did not weaken accountability over federal funds for 

salaries and wages; an audit of the third university was inconclusive, and 

the fourth audit report had not been issued as of April 2016.40

In April 2016, OMB staff said other reforms in the Uniform Guidance also 

reduced administrative workload and costs by providing universities and 

other grantees more flexibility. For example, the Uniform Guidance 

includes provisions specifically allowing the use of fixed amount awards—

grant agreements for which accountability is based primarily on 

performance and results rather than accounting for incurred costs—which 

OMB staff said can reduce administrative workload and costs, for 

example, for submission of invoices by the fixed amount award 

recipient.41 Also, in the Uniform Guidance, OMB clarified its prior 

guidance by detailing the conditions under which grantees may directly 

charge administrative support costs to grants—rather than being 

 40Audit reports for George Mason University and Michigan Technological University found 

that the universities’ implementation of payroll certification did not weaken accountability 

over federal funds for salaries and wages. See National Science Foundation Office of 

Inspector General, Labor Effort Reporting under the Federal Demonstration Project’s Pilot 

Payroll Certification Program at George Mason University, 15-1-017 (July 31, 2015) and 

Labor Effort Reporting under the Federal Demonstration Partnership Pilot Payroll 

Certification at Michigan Technological University, 15-1-023 (Sept. 30, 2015). The audit 

report for the University of California, Irvine was inconclusive regarding whether its pilot 

system provided accountability over salary and wage charges, because the auditors could 

not reconcile certain university accounting records. See Department of Health and Human 

Services Office of Inspector General, The University of California at Irvine’s Pilot Payroll 

Certification System Could Not Be Assessed, A-04-13-01027 (Dec. 2014). The audit 

report for the University of California, Riverside had not been issued as of April 2016.

41Under fixed amount awards, payments are based on meeting specific requirements of 

the award, and there is no agency review of the actual costs incurred. Awarding agencies 

or pass-through entities may use fixed amount awards if the project scope is specific and 

if adequate cost, historical, or unit pricing data are available to establish a fixed amount 

award.
Page 37 GAO-16-573 Federal Research Grants

reimbursed for these costs as part of their indirect (or overhead) costs.42

OMB staff said this change reduced administrative workload and costs by 

better allowing universities to assign administrative staff to specific 

research projects so that researchers can focus more of their time on the 

scientific aspects of the projects. However, fixed amount awards and 

direct charging of administrative support costs were both allowed under 

certain circumstances prior to the Uniform Guidance, and we did not 

specifically discuss the reforms with universities, so we do not know to 

what extent universities believe the reforms reduced their administrative 

workload and costs.

Despite efforts to allow universities more flexibility, as previously 

discussed, several administrative requirements—in particular, OMB 

requirements related to purchases and subrecipients and NIH 

requirements related to financial conflicts of interest—limit universities’

flexibility and require them to allocate administrative resources toward 

oversight of lower-risk purchases, subrecipients, and financial interests. 

These requirements limit universities’ flexibility in the following ways:

• Competition and documentation of purchases. In developing the 

Uniform Guidance, OMB established the micro-purchase threshold—

above which grantees must generally obtain price or rate quotations, 

competitive bids, or competitive proposals—based on the threshold 

for competition of purchases made under federal contracts.43

University officials said that prior to the Uniform Guidance, the 

universities had set their thresholds based on consideration of the 

potential savings and administrative costs of competition or, in the 

case of public universities, state requirements. As previously 

 42OMB’s prior guidance required administrative costs to be charged indirectly but 

otherwise provided that costs are direct when they may be specifically allocated to one 

award. The Uniform Guidance requires that salaries of administrative and clerical staff 

normally be treated as indirect costs, but that direct charging of these costs may be 

appropriate if they are (1) integral to a project or activity, (2) for individuals who can be 

specifically identified with the project or activity, (3) explicitly included in the budget or 

have the prior written approval of the awarding agency, and (4) not also recovered as 

indirect costs.

43The Uniform Guidance defines the micro-purchase threshold as the threshold set by the 

Federal Acquisition Regulation at 48 C.F.R. Subpart 2.1 (Definitions). It is $3,000 except 

as otherwise discussed in Subpart 2.1 of that regulation, but this threshold is periodically 

adjusted for inflation. See 2 C.F.R. § 200.67. At the time of our report, the threshold was 

$3,500.
Page 38 GAO-16-573 Federal Research Grants

discussed, officials at five of the universities in our review told us that 

they had each established a higher threshold than the Uniform 

Guidance for obtaining multiple quotations. Furthermore, officials from 

the six universities in our review said that for relatively small 

purchases, the administrative workload and costs associated with 

competition may outweigh the savings gained.

• Monitoring subrecipients. In developing the Uniform Guidance, 

OMB largely based its subrecipient monitoring requirements on those 

in its prior guidance and did not provide certain flexibilities to grantees 

to assess and manage risks. Specifically, the Uniform Guidance 

allows grantees to use a risk-based approach to monitor 

subrecipients, but it does not allow a risk-based approach to following 

up on audit findings that pertain to the subaward. The requirement for 

a university to follow up on audit findings is not risk based in that it 

applies to all subrecipients, regardless of their risk as assessed by the 

university. Officials we interviewed from the six universities in our 

review and stakeholder organizations generally agreed that 

administrative resources spent reviewing and following up on audits of 

low-risk subrecipients, such as those that have long track records of 

conducting federally funded research, could be better targeted on 

monitoring higher-risk subrecipients. These officials also noted that 

because the Uniform Guidance requires universities to review 

financial and performance reports and perform other project-level 

oversight of subrecipients, following up on audit findings may result in 

little added protection against improper use of funds and poor 

performance. OMB staff said that they have drafted an audit reporting 

form that universities can use to reduce the workload of reviewing 

subrecipients’ audit reports. However, the form had not been issued 

as of April 2016, and the draft form does not change the requirement 

for universities to follow up on audit findings for all subrecipients, 

regardless of risk.

• Identifying and managing researcher financial conflict of interest. 

Under the HHS regulations governing NIH’s conflict of interest 

requirements, researchers must disclose to their institution a range of 

financial interests held by them, their spouses, or their dependent 

children. These financial interests include investments in or income 

from a company involved in similar research, patents or copyrights 

that generate income for the researcher, or reimbursed or sponsored 

travel, among others. These different types of financial interests vary 

in the frequency with which they occur and in the risk they might pose 

to the integrity of the NIH-funded research. Officials we interviewed 

from the six universities in our review and stakeholder organizations 

generally agreed that the additional financial interests that must be 
Page 39 GAO-16-573 Federal Research Grants

disclosed and reviewed under the revised requirements—particularly 

reimbursed or sponsored travel costs, which officials said are 

common among academic researchers—rarely result in identification 

of actual conflicts that could bias their research.

OMB, in developing the Uniform Guidance, and HHS, in developing the 

financial conflict of interest regulations that apply to NIH awards, each 

went through multiyear public rule-making processes and incorporated 

input from a range of stakeholders concerned about administrative 

workload and costs as well as accountability and research integrity. OMB 

plans to evaluate the guidance’s overall impact on burden and waste, 

fraud, and abuse by January 2017 to identify opportunities to enhance its 

effectiveness. Similarly, as stated in the final rule for its conflict of interest 

regulation, HHS plans to evaluate the effects of certain provisions of the 

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

stakeholder organizations, have begun collecting information on the 

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

directed agencies to report, beginning in January 2015, information on 

their implementation of the Uniform Guidance, including metrics on the 

overall impact on burden and waste, fraud, and abuse.44 In addition, the 

Federal Demonstration Partnership has gathered information from 

member universities to report to OMB on how the Uniform Guidance 

purchasing requirements will affect universities’ administrative workload 

and costs. Similarly, the Association of American Medical Colleges has 

gathered information from its member institutions on how HHS’s new 

regulation has affected their administrative workload and costs for 

disclosing and reviewing financial interests, and how it has affected the 

number of actual conflicts of interest institutions have identified. The 

additional information agencies and stakeholder organizations are 

gathering could allow OMB and HHS to more fully consider the 

requirements’ effects on universities’ administrative workload and costs 

and balance such considerations against the requirements’ added 

protections for accountability and research integrity.

Federal standards for internal control call for agencies to identify risks, 

analyze them to estimate their significance, and respond to them based 

 44Office of Management and Budget, Metrics for Uniform Guidance (2 C.F.R. 200), OMB 

Memorandum M-14-17 (Washington, D.C.: Sept. 30, 2014).
Page 40 GAO-16-573 Federal Research Grants

on their significance and the agency’s risk tolerance.45 The standards also 

state that management may need to conduct periodic risk assessments to 

evaluate the effectiveness of risk response actions. Neither OMB nor 

HHS has specified whether its evaluation of the Uniform Guidance and 

financial conflict of interest regulations, respectively, will include 

evaluating options for targeting requirements on areas of greatest risk, 

particularly in the areas of competing and documenting purchases, 

monitoring subrecipients, or identifying and managing research conflict of 

interest. Evaluating such options could help universities focus 

administrative resources on areas of highest risk and allow researchers to 

maximize the time spent on conducting research versus completing 

administrative tasks.

OMB and research funding agencies—in response to congressional or 

executive directives—have established administrative requirements on 

research grants. Such requirements help to protect against waste, fraud, 

and abuse of funds and to promote the quality and effectiveness of 

federally funded research, but they also create administrative workload 

and costs for universities. OMB and funding agencies have made a 

number of efforts to reduce workload and costs—such as by 

standardizing requirements across agencies, streamlining pre-award 

requirements, and allowing universities more flexibility to manage risks—

and have had some success.

However, opportunities remain for research funding agencies to achieve 

additional reductions in administrative workload and costs while still 

protecting against waste, fraud, and abuse. RBM—whose charter calls for 

it to examine opportunities and develop and report on options to unify and 

streamline agency research grants administration practices—is well 

suited to pursue such efforts. First, agencies have opportunities to 

standardize requirements through RBM to a greater extent than they have 

already done, by addressing variations in budget forms, biographical 

sketches, and conflict of interest requirements, among others. Such 

standardization could reduce universities’ administrative workload and 

costs associated with investing in systems and spending researcher and 

 45GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sept. 2014).

Conclusions
Page 41 GAO-16-573 Federal Research Grants

administrative staff time learning and complying with agencies’ varying 

requirements. Second, NSF senior leadership has called for an agencywide review to identify options for expanding preliminary proposals or 

other pre-award streamlining efforts, but DOE, NASA, and NIH have not 

called for similar reviews. Agency-wide reviews to identify opportunities to 

use preliminary proposals or similar approaches where applicable could 

reduce administrative workload and costs associated with proposal 

preparation, particularly for the large majority of applicants that do not 

receive awards.

Opportunities also remain for OMB and HHS to reduce administrative 

workload and costs by allowing universities more flexibility to assess and 

manage risks related to certain administrative requirements, as they have 

already done with requirements for documenting personnel expenses and 

preparing and managing budgets and as called for in federal streamlining 

directives. Specifically, (1) OMB’s planned evaluation of the Uniform 

Guidance presents an opportunity for OMB to consider targeting 

requirements for purchasing and subrecipient monitoring on areas of 

greatest risk to proper use of research funds and (2) HHS’s planned 

evaluation of its revised conflict of interest requirements presents an 

opportunity for HHS to consider targeting conflict of interest requirements 

on areas of greatest risk to research integrity. By evaluating options for 

targeting these requirements, OMB and HHS may identify ways to reduce 

universities’ administrative workload and costs while maintaining 

accountability over grant funds.

We are making four recommendations for identifying and pursuing 

opportunities to streamline administrative requirements on research 

grants to universities.

To further standardize administrative research requirements, the 

Secretary of Energy, the NASA Administrator, the Secretary of Health and 

Human Services, and the Director of NSF should coordinate through 

OSTP’s Research Business Models working group to identify additional 

areas where they can standardize requirements and report on these 

efforts.

To reduce pre-award administrative workload and costs, particularly for 

applications that do not result in awards, the Secretary of Energy, the 

NASA Administrator, and the Secretary of Health and Human Services

should conduct agency-wide reviews of possible actions, such as further 

use of preliminary proposals, to postpone pre-award requirements until 

Recommendations for 

Executive Action
Page 42 GAO-16-573 Federal Research Grants

after a preliminary decision about an applicant’s likelihood of funding and, 

through OSTP’s Research Business Models working group, coordinate 

and report on these efforts.

To better target requirements on areas of greatest risk, while maintaining 

accountability over grant funds,

• the Secretary of Health and Human Services, as part of the planned 

evaluation of the HHS regulation governing financial conflicts of 

interest in NIH-funded research, should evaluate options for targeting 

requirements on areas of greatest risk for researcher conflicts, 

including adjusting the threshold and types of financial interests that 

need to be disclosed and the timing of disclosures, and

• the Director of OMB, as part of OMB’s planned evaluation of the 

Uniform Guidance, should evaluate options for targeting requirements 

for research grants to universities, including requirements for 

purchases and subrecipient monitoring, on areas of greatest risk for 

improper use of research funds.

We provided a draft of this report to DOE, HHS, NASA, NSF, OMB, and 

OSTP. DOE, HHS—responding on behalf of NIH—and NASA provided 

written comments, which are reproduced in appendixes V, VI, and VII, 

respectively, and NSF and OMB provided oral comments. DOE, HHS, 

and NASA generally concurred with our findings and recommendations 

and provided specific comments which we discuss in more detail below. 

NSF and OMB did not comment on our recommendations. DOE, HHS, 

NSF, and OMB also provided technical comments, which we incorporated 

as appropriate.

DOE, HHS, and NASA concurred with our first recommendation to 

coordinate through RBM to identify additional areas where they can 

standardize requirements. In their comments, the agencies said they 

would continue to build on RBM’s previous efforts to standardize 

requirements and report on their efforts according to RBM’s charter. NSF 

did not formally state whether it concurred with the recommendation, but 

NSF officials told us that research funding agencies already coordinate 

effectively through RBM and other groups, on such efforts as the 

standard research terms and conditions and the Research Performance 

Progress Report. However, these current efforts are expected to be 

complete in late 2016 or early 2017, and we continue to believe that 

agencies have opportunities to standardize requirements in areas that 

Agency Comments 

and Our Evaluation
Page 43 GAO-16-573 Federal Research Grants

have not yet been addressed by current efforts, and achieve additional 

reductions in administrative workload and costs while still protecting 

against waste, fraud, and abuse.

DOE and HHS concurred, and NASA partially concurred, with our second 

recommendation to conduct agency-wide reviews of possible actions to 

postpone pre-award requirements until after a preliminary decision about 

an applicant’s likelihood of funding. DOE stated that it would review preaward requirements and coordinate through RBM to define actions to be 

taken to reduce burdens of these requirements, and HHS stated that NIH 

will review what components of grant applications are strictly needed to 

provide information for balanced and fair review and funding 

considerations, and what components can be added to the information 

requested during the just-in-time stage. In its technical comments, HHS 

stated that in 2014, NIH charged its Scientific Management Review Board 

to conduct an evaluation to recommend ways to further optimize the 

process of reviewing, awarding, and managing grants and maximize the 

time researchers can devote to research.46 In line with our second 

recommendation, the Board’s report also found that the use of preliminary 

proposals could be expanded and included a recommendation that NIH 

pilot test preliminary proposals. In its comments, NASA agreed to review 

existing documents and reports to identify best practices that postpone 

pre-award requirements, but stated that program offices should determine 

whether or not these practices are in the best interest of the program 

mission. We acknowledge in our report that preliminary proposals may 

not be effective in reducing administrative workload and costs for certain 

research grant programs or solicitations, and our recommendation allows 

for program offices to use discretion in determining what actions to take, if 

any, to postpone pre-award requirements until after a preliminary decision 

about an applicant’s likelihood of funding. 

HHS concurred with our third recommendation to evaluate options for 

targeting its financial conflict of interest requirements on areas of greatest 

risk for researcher conflicts. HHS stated in its comments that it has 

partnered with the Association of American Medical Colleges to measure 

 46NIH, Scientific Management Review Board, Report on Streamlining the NIH Grant 

Review, Award, and Management Process (July 2015).
Page 44 GAO-16-573 Federal Research Grants

the effectiveness of the financial conflict of interest requirements and 

identify areas that may create administrative burden. 

OMB did not formally state whether it concurred with our fourth 

recommendation to evaluate options for targeting requirements for 

purchases and subrecipient monitoring on areas of greatest risk for 

improper use of research funds. However, OMB staff told us that they 

agree that opportunities remain for streamlining administrative 

requirements. In addition, in technical comments on our draft, OMB staff 

stated that its grants policy applies to all types of grants and recipients—

not just research grants to universities. We have revised our report to 

clarify that OMB’s requirements apply to all types of grants and recipients. 

With regard to our recommendation, it is important to note that the 

Uniform Guidance states that OMB may allow exceptions to requirements 

for classes of federal awards or recipients—for example, when doing so 

would expand or improve the use of effective practices in delivering 

federal financial assistance. We believe that our recommendation that 

OMB evaluate options for targeting requirements for research grants to 

universities could lead to such improvements for universities and 

potentially for other types of recipients. In particular, if implemented by 

OMB, our recommendation could help universities focus administrative 

resources on areas of highest risk and allow researchers to maximize the 

time spent on conducting research versus completing administrative 

tasks.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate 

congressional committees, the Director of the National Science 

Foundation, the Director of the Office of Management and Budget, the 

Director of the Office of Science and Technology Policy, the Secretary of 

Energy, the Secretary of Health and Human Services, the Administrator 

of the National Aeronautics and Space Administration, and other 

interested parties. In addition, the report will be available at no charge on 

the GAO website at http://www.gao.gov.
Page 45 GAO-16-573 Federal Research Grants

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 VIII.

John Neumann

Director, Natural Resources and Environment
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-16-573 Federal Research Grants

This report examines (1) the sources and goals of selected research 

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

administrative workload and costs for complying with these requirements, 

and (3) efforts the Office of Management and Budget (OMB) and 

research funding agencies have made to reduce the administrative 

workload and costs for complying with these requirements, and the 

results of these efforts.

To address these objectives, we selected four agencies that fund 

research grants to universities and focused on nine categories of 

requirements associated with these agencies’ research grants:

• The four funding agencies were the Department of Energy (DOE), 

National Aeronautics and Space Administration (NASA), National 

Institutes of Health (NIH) within the Department of Health and Human 

Services, and National Science Foundation (NSF). We selected NIH 

and NSF because they are the two largest funders of research at 

universities and colleges, according to NSF data. We selected DOE 

and NASA as two agencies providing smaller amounts of research 

funding, and funding for different types of research, to universities and 

colleges. According to NSF data, these four agencies provided about 

83 percent of federal funding for research at universities and colleges 

in fiscal year 2015. Our findings from our reviews of these four 

agencies cannot be generalized to all agencies that fund research.

• The nine categories of administrative requirements on research grants 

were (1) competition and documentation of purchases, (2) 

documenting personnel expenses, (3) preparing and managing 

project budgets, (4) subaward reporting, (5) subrecipient monitoring, 

(6) biographical sketches, (7) financial conflicts of interest, (8) 

managing and sharing research data and results, and (9) researcher 

mentoring and development. We chose these requirements based on 

several factors. In particular, we chose requirements that multiple 

universities and university stakeholder organizations had cited as 

contributing to universities’ administrative workload or costs. In 

addition, we chose requirements that had been the subject of recent 

streamlining efforts or of recent changes in OMB or funding agency 

guidance, or that had been part of the findings of recent reports by 

agency inspectors general on research grants to universities. Our 

findings from our reviews of these requirements cannot be 

generalized to all administrative requirements. See appendix II for 

more information on these requirements, including their definitions, 

sources, and goals.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-16-573 Federal Research Grants

To examine the sources and goals of these nine categories of 

requirements, we reviewed documents related to establishing the 

requirements and any changes that had been made. These documents 

included public laws; Federal Register notices and other documentation 

related to OMB’s development of the Uniform Administrative 

Requirements, Cost Principles, and Audit Requirements for Federal 

Awards (Uniform Guidance); and other documentation of governmentwide requirements, such as the February 2013 Office of Science and 

Technology Policy (OSTP) memorandum on increasing access to the 

results of federally funded scientific research. We also examined DOE, 

NASA, NIH, and NSF documents related to their implementation of the 

nine categories of requirements, including agency-specific guidance on 

grant proposal and award policies and procedures and agency 

regulations implementing the Uniform Guidance. To ensure the accuracy 

and completeness of the information we collected, we obtained input from 

the four agencies in our scope by obtaining their edits and additions to a 

matrix we prepared summarizing the sources and goals of the nine 

requirements. For further information, we interviewed OMB staff about the 

development of the Uniform Guidance, including its provisions specific to 

university research grants, and we interviewed DOE, NASA, NIH, and 

NSF officials responsible for developing research grant requirements at 

their agencies. We also reviewed audit reports issued by the DOE, NASA, 

NIH, and NSF offices of inspector general related to research grants and 

the nine categories of requirements included in our scope to determine 

how the inspectors general apply the requirements, and we interviewed 

office of inspector general officials from each of the four agencies.

To examine factors that contribute to universities’ administrative workload 

and costs for complying with selected requirements, we selected a 

nongeneralizable sample of six universities to conduct in-depth interviews 

of officials regarding each of the nine categories of requirements in our 

scope and to collect qualitative information on the types of administrative 

workload and costs resulting from the requirements—such as 

administrative staff costs, researcher time, and investments in systems 

and processes. The six universities were George Mason University; 

Johns Hopkins University; Massachusetts Institute of Technology; 

University of California, Riverside; University of Massachusetts, Amherst; 

and University of Southern California. We selected these universities 

because they ranged in the amount of federal research funding they 

received in fiscal year 2014, as reported by NSF, and because they 

provided a diverse sample that included both public and private 

institutions and both member and nonmember institutions in the Federal 

Demonstration Partnership—a cooperative initiative of 10 federal 
Appendix I: Objectives, Scope, and 

Methodology

Page 48 GAO-16-573 Federal Research Grants

agencies and 155 university recipients of federal funds that works to 

reduce the administrative burdens associated with research grants and 

contracts. We also considered whether these universities had participated 

in pilot streamlining efforts related to one or more of the nine categories of 

requirements included in our scope.

At each of the six universities, we reviewed university policies for 

implementing federal requirements and other relevant documentation, 

and we interviewed officials from the central offices for administration of 

grants, principal investigators who led research projects funded by grants, 

and administrators within the academic departments where principal 

investigators hold positions. In particular, we discussed the officials’ views 

on the effects of prior, current, and proposed changes to requirements 

and their suggestions for streamlining requirements. For further context 

on universities’ administrative workload and costs, including suggestions 

for streamlining and views on changes to requirements, we interviewed 

officials from and reviewed studies conducted by the following 

stakeholder organizations: the Association of American Medical Colleges, 

Council on Governmental Relations, Federal Demonstration Partnership, 

Federation of American Societies for Experimental Biology, National 

Academy of Sciences, and National Science Board. We identified these 

organizations based on discussions with agency and university officials 

and reviews of published reports, and selected those that had studied 

administrative workload and costs related to our selected categories of 

requirements.

To examine OMB and agency efforts to reduce the administrative 

workload and costs for complying with the requirements included in our 

scope and the results of these efforts, we focused on government-wide 

efforts led by OMB and OSTP as well as on agency-specific efforts at 

DOE, NASA, NIH, and NSF. We identified current and past streamlining 

efforts by reviewing agency documents, attending presentations by 

agency officials at Federal Demonstration Partnership and other public 

meetings, and interviewing OMB and OSTP staff as well as officials from 

the four research funding agencies in our scope. To determine the results 

of these streamlining efforts, we reviewed agency documents, including 

assessments of the results of their efforts, and interviewed agency and 

university officials. We also interviewed agency officials regarding 

government-wide efforts to coordinate development and implementation 

of requirements among agencies and the feasibility of suggestions for 

streamlining requirements. We interviewed OMB staff regarding their 

plans to review the effects of the Uniform Guidance, including the effects 

on universities’ administrative workload and costs, and we interviewed 
Appendix I: Objectives, Scope, and 

Methodology

Page 49 GAO-16-573 Federal Research Grants

OSTP and agency officials on streamlining and coordination efforts by the 

Research Business Models working group within the National Science 

and Technology Council’s Committee on Science. Finally, we interviewed 

officials from offices of inspectors general at the four funding agencies in 

our scope about the potential effects of changes to requirements on the 

ability of grant-making agencies to ensure transparency and 

accountability, and about the NIH and NSF inspector general audits of a 

pilot program at four universities to streamline requirements for 

documenting personnel expenses.

We conducted this performance audit from April 2015 to June 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.
Appendix II: Sources and Goals of Selected 

Administrative Requirements

Page 50 GAO-16-573 Federal Research Grants

Table 3 lists the sources and goals of selected administrative grant 

requirements.

Table 3: Sources and Goals of Selected Administrative Requirements

Requirement 

category Description Primary goal

Selected agencies 

implementing 

requirements Sources

Competition and 

documentation 

of purchases

Requirements for 

grantees to obtain 

price or rate 

quotations, 

competitive bids, or 

competitive proposals 

for certain purchases 

of goods and services 

made using grant 

funds, and to 

document such 

purchases.

For competition 

requirements: to ensure that 

procurement transactions are 

conducted in a manner 

providing full and open 

competition.

For documentation 

requirements: to ensure that 

grantees maintain records 

sufficient to detail the history 

of procurement.

• Office of 

Management 

and Budget 

(OMB)

• Department of 

Energy (DOE)

• National 

Aeronautics and 

Space 

Administration 

(NASA)

• National 

Institutes of 

Health (NIH)

• National 

Science 

Foundation 

(NSF)

OMB’s Uniform Administrative 

Requirements, Cost Principles, and 

Audit Requirements for Federal 

Awards (Uniform Guidance) contains 

government-wide purchasing 

competition and documentation 

requirements.

a OMB delayed 

implementation of the Uniform 

Guidance purchasing requirements 

for 2 full fiscal years after the effective 

date of the Uniform Guidance. These 

requirements will become effective for 

universities sometime in 2017, 

depending on universities’ fiscal 

calendars.

The four funding agencies in our 

review implemented the Uniform 

Guidance through agency 

regulations, guidance, and the terms 

and conditions of their awards.

Documenting 

personnel 

expenses

Requirements for 

grantees to maintain 

documentation and 

systems to support 

charges to federal 

awards for salaries 

and wages.

To ensure that the grantees’

accounting practices with 

respect to salary and wage 

charges to federal awards 

are consistent with federal 

cost principles.

• OMB

• DOE

• NASA

• NIH

• NSF

OMB’s Uniform Guidance contains 

government-wide requirements for 

documenting personnel expenses.

The four funding agencies in our 

review implemented the Uniform 

Guidance through agency 

regulations, guidance, and the terms 

and conditions of their awards.

Appendix II: Sources and Goals of Selected 

Administrative Requirements
Appendix II: Sources and Goals of Selected 

Administrative Requirements

Page 51 GAO-16-573 Federal Research Grants

Requirement 

category Description Primary goal

Selected agencies 

implementing 

requirements Sources

Preparing and 

managing 

project budgets

Requirements for how 

applicants must 

develop and justify 

research project 

budgets and submit 

them to agencies; for 

how grantees may 

modify and manage 

budgets; and for how 

grantees must report 

on the use of funds 

over the course of 

research projects. 

For pre-award budget 

preparation requirements: to 

allow agencies to determine 

whether requested funds are 

reasonable, allocable, and 

allowable in accordance with 

cost principles for federal 

awards.

For post-award budget 

management requirements: 

to allow agencies to ensure 

compliance with statutory 

and public policy

requirements, the terms and 

conditions of the award, and 

cost principles for federal 

awards.

• OMB

• DOE

• NASA

• NIH

• NSF

OMB’s Uniform Guidance contains 

government-wide budget preparation 

and management requirements.

The four funding agencies in our 

review implemented the Uniform 

Guidance through agency 

regulations, guidance, and the terms 

and conditions of their awards. The 

agencies have additional 

requirements related to budget 

preparation and management, such 

as requirements for the specific 

information and forms used to collect 

proposal budgets, the types of postaward budget revisions recipients can 

make, and the systems for financial 

reporting.

Subaward 

reporting

Requirements for 

primary grant 

recipients to report 

information to 

agencies on 

subawards made to 

institutions helping 

conduct research.

To ensure full disclosure of 

entities receiving federal 

funding.

• OMB

• DOE

• NASA

• NIH

• NSF

OMB’s Uniform Guidance requires 

agencies and grantees to comply with 

the Federal Funding Accountability 

and Transparency Act of 2006, which 

contains government-wide subaward

reporting requirements, including that 

recipients report subaward 

information and agencies make it 

available on a public website.b

The four funding agencies in our 

review implemented the Uniform 

Guidance through agency 

regulations, guidance, and the terms

and conditions of their awards.

Subrecipient 

monitoring

Requirements for 

primary grant 

recipients to evaluate 

the risk of 

subrecipients’

noncompliance with 

federal statutes, 

regulations, and the 

terms and conditions 

of subawards, and to 

monitor subrecipient 

activities accordingly. 

To ensure that subaward 

funds are used for authorized 

purposes, in compliance with 

federal statutes, regulations, 

and the terms and conditions 

of the subaward, and that the 

subaward performance goals 

are achieved.

• OMB

• DOE

• NASA

• NIH

• NSF

OMB’s Uniform Guidance contains 

government-wide subrecipient 

monitoring requirements.

The four funding agencies in our 

review implemented the Uniform 

Guidance through agency 

regulations, guidance, and the terms 

and conditions of their awards.
Appendix II: Sources and Goals of Selected 

Administrative Requirements

Page 52 GAO-16-573 Federal Research Grants

Requirement 

category Description Primary goal

Selected agencies 

implementing 

requirements Sources

Biographical 

sketches

Requirements for 

applicants to submit 

information on the 

experience, 

publications, and 

accomplishments of 

project personnel as 

part of research grant 

proposals.

To provide application 

reviewers with the 

information necessary to 

assess applicants’

qualifications to carry out the 

proposed research.

• DOE

• NASA

• NIH

• NSF

The four funding agencies in our 

review generally implemented 

requirements for biographical 

sketches through agency guidance. 

Financial 

conflicts of 

interestc

Requirements for 

applicants and 

grantees to identify, 

report, and manage 

researchers’ financial 

conflicts of interest.

To promote research 

objectivity by establishing 

standards to protect against 

bias in the design, conduct, 

and reporting of research.

• NASA

• NIH

• NSF

NASA and NSF established 

requirements for financial conflicts of 

interest in agency guidance.

The Department of Health and 

Human Services (HHS), with input 

from NIH, revised its regulations 

governing financial conflict of interest 

for research funded by NIH and other 

HHS agencies, in part in response to 

Congressional directives.

d NIH 

implemented these requirements 

through agency guidance.

Managing and 

sharing research 

data and results

Requirements for 

applicants to develop 

and submit to 

agencies plans to 

manage and share 

data products, 

publications, or other 

information resulting 

from grant-funded 

research, and for 

grantees to comply 

with those plans over 

the course of research 

projects.

To ensure that the direct 

results, including digital data, 

of federally funded scientific 

research are made available 

to and useful for the public, 

industry, and the scientific 

community.

• Office of 

Science and 

Technology 

Policy (OSTP)

• DOE

• NASA

• NIH

• NSF

An OSTP memorandum provides the 

principal government-wide guidance 

on management and sharing of 

research results and data.e

The four funding agencies in our 

review developed and implemented 

plans to support increased public 

access to the results of research they 

fund, as the OSTP memorandum 

directed. These plans specify data 

management requirements for 

grantees.
Appendix II: Sources and Goals of Selected 

Administrative Requirements

Page 53 GAO-16-573 Federal Research Grants

Requirement 

category Description Primary goal

Selected agencies 

implementing 

requirements Sources

Researcher 

mentoring and 

development

Requirements for 

applicants to develop 

and submit to 

agencies plans to 

mentor and develop 

researchers, and for 

grantees to comply 

with those plans over 

the course of research 

projects.

For NIH’s requirement, 

based on agency guidance: 

to assist graduate students 

and postdoctoral researchers 

in achieving their career 

goals and becoming 

contributing members of the 

biomedical workforce.

For NSF’s requirement, 

based on agency guidance: 

to support researchers’

career development in areas 

such as research 

management, publishing, 

and collaboration, as well as 

teaching and mentoring.

• NIH

• NSF

NIH guidance encourages institutions 

to use individual development plans 

to identify and promote the career 

goals of graduate students and 

postdoctoral researchers associated 

with NIH awards, and requires 

grantees using individual 

development plans to describe their 

use of these plans in annual progress 

reports.

NSF established its requirements for 

postdoctoral mentoring plans in 

agency guidance, as directed by 

Congress in the America Creating 

Opportunities to Meaningfully 

Promote Excellence in Technology, 

Education, and Science Act of 2007.f

Source: GAO analysis of OMB, OSTP, and research funding agency guidance and regulations. | GAO-16-573

a

OMB consolidated its grants management circulars into a single document, the Uniform Guidance, in 

2013. 78 Fed. Reg. 78,590 (Dec. 26, 2013).

b

Pub. L. No. 109-282, 120 Stat. 1186 (2006) as amended.

c

We focused our review on agency requirements related to conflicts of interest that could bias the 

conduct of research, such as medical researchers with financial ties to pharmaceutical companies 

that might be affected by research results. The Uniform Guidance does not establish specific 

requirements for how grantees must identify and manage conflicts of interest, although it contains a 

general provision for agencies to establish policies that apply to conflicts that might arise around how 

recipients expend award funds, and a requirement that the grantee must disclose in writing any 

potential conflict of interest to the federal awarding agency or pass-through entity in accordance with 

applicable awarding agency policy.

d

Pub. L. No. 111–117, Div. D, Title II, § 219, 123 Stat. 3259 (2009). The HHS regulations appear at 

76 Fed. Reg. 53256 (Aug. 25, 2011).

e

Director of the Office of Science and Technology Policy, Increasing Access to the Results of 

Federally Funded Scientific Research, Memorandum for the Heads of Executive Departments and 

Agencies from John P. Holdren, (Feb. 22, 2013).

f

Pub. L. No. 110-69, Title VII, § 7008, 121 Stat. 680 (2007).
Appendix III: Examples of Differences in 

Selected Administrative Requirements across 

Agencies in GAO’s Review

Page 54 GAO-16-573 Federal Research Grants

Table 4 shows examples of differences in selected administrative 

requirements across agencies in our review.

Table 4: Examples of Differences in Selected Administrative Requirements across Agencies in GAO’s Review

Department of Energy 

(DOE)

National Aeronautics and 

Space Administration (NASA)

National Institutes of Health 

(NIH)

National Science Foundation 

(NSF)

Financial conflict of interest

N/Aa Recipients must maintain written 

conflict of interest standards that 

establish what financial interests 

are not substantial and what 

disciplinary actions are to be 

applied for violations of the 

standards.

Researchers must generally 

disclose the following types of 

financial interests to their

institutions, among others:b

• interests that reasonably 

appear to be related to their 

institutional responsibilities, 

including activities such as 

research, research 

consultation, teaching, 

professional practice, and 

institutional committee 

memberships;

• reimbursed or sponsored 

travel costs, including the 

purpose, duration, 

destination, and sponsor of 

the trip; and

• income from non-profit 

entities.

The threshold for interests that 

researchers must disclose is 

generally $5,000, or any amount 

of equity in non-publicly traded 

entities.

Institutions must report all 

conflicts to NIH unless they are 

eliminated prior to the 

expenditure of funds.

The Department of Health and 

Human Services’ regulation 

includes additional requirements 

for researcher training, 

retrospective review of conflicts 

identified that had not been 

managed as required when 

research was being conducted, 

and making public any identified 

conflicts for senior personnel.

Researchers must generally 

disclose the following types of 

financial interests to their 

institutions, among others:c

• interests that reasonably 

appear to be affected by the 

NSF-funded research, or 

that are in entities whose 

financial interests reasonably 

appear to be affected by 

such activities.

Researchers are generally not 

required to disclose the following 

interests, among others:

• reimbursed or sponsored 

travel costs (no specific 

disclosure requirement) and

• income from non-profit 

entities for certain activities.

The threshold for interests that 

researchers must disclose is 

generally interests in excess of 

$10,000, or in excess of 5 

percent ownership interest in a 

single entity.

Institutions must report conflicts 

to NSF only if they cannot be 

satisfactorily managed, reduced, 

or eliminated or if research will 

proceed without the imposition of 

conditions on the conflicts.

NSF’s policy does not specifically 

require researcher training, 

retrospective review of conflicts 

identified after research has been 

conducted, or making public any 

identified conflicts, but provides 

examples of conditions to 

manage or reduce conflicts, 

including public disclosure or 

monitoring of the research.

Biographical sketches

Appendix III: Examples of Differences in 

Selected Administrative Requirements 

across Agencies in GAO’s Review
Appendix III: Examples of Differences in 

Selected Administrative Requirements across 

Agencies in GAO’s Review

Page 55 GAO-16-573 Federal Research Grants

Department of Energy 

(DOE)

National Aeronautics and 

Space Administration (NASA)

National Institutes of Health 

(NIH)

National Science Foundation 

(NSF)

Formatting requirements: 

two-page limitd

Content requirements 

include:d

• List of publications: up 

to 10

• Information about 

research collaborators: 

list in alphabetical order 

all persons who have 

been collaborators in 

the 48 months prior to 

submission of 

application

• List of 

academic/professional 

positions: chronological 

order

Formatting requirements: twopage limit

Content requirements include:

• List of publications: no limit

• Information about research 

collaborators: one page per 

co-investigator

• List of academic/professional 

positions: none

Formatting requirements: fivepage limit

Content requirements include:

• List of publications: up to 24

• Information about research 

collaborators: none

• List of academic/professional 

positions: chronological 

order

Formatting requirements: twopage limit; must use certain fonts

Content requirements include:

• List of publications: up to 10

• Information about research 

collaborators: none

• List of academic/professional 

positions: reverse 

chronological order

Budget preparation

Each of the budget forms listed below has a different format, set of line items, and set of instructions. The level of detail also varies 

among forms, with NIH’s modular budget form requiring relatively little budget detail, the government-wide Standard Form 424 (SF424) research and related budget form requiring an intermediate amount of detail, and DOE’s Office of Energy Efficiency and 

Renewable Energy budget form requiring relatively detailed budget information. Some forms require applicants to list indirect costs 

individually, while one form requires applicants to group indirect costs together. In addition, some forms require applicants to provide 

information on the type of work and reason for subawards, while other forms only require applicants to list the subaward cost amount.

Budget forms:

• SF-424 research and 

related budget form for 

Grants.gov applications

• DOE’s Office of Energy

Efficiency and 

Renewable Energy 

budget form for 

applications submitted 

to that office’s 

electronic grant 

proposal submission 

system

• DOE’s Advanced 

Research Projects 

Agency—Energy 

budget form and 

questionnaire for 

applications submitted 

to that agency’s 

electronic grant 

proposal submission 

system

Budget forms:

• SF-424 research and 

related budget form for 

Grants.gov applications

• NASA Research 

Education and Support 

Services budget form 

for applications 

submitted to NASA’s 

electronic grant 

proposal submission 

system 

Budget forms:

• SF-424 research and related 

budget form for Grants.gov 

applications requesting 

$250,000 or more per year

• NIH’s modular budget form for 

Grants.gov applications 

requesting up to $250,000 per 

year

Budget forms:

• SF-424 research and related 

budget form for Grants.gov 

applications

• NSF budget form for 

applications submitted to 

NSF’s electronic grant 

proposal submission system
Appendix III: Examples of Differences in 

Selected Administrative Requirements across 

Agencies in GAO’s Review

Page 56 GAO-16-573 Federal Research Grants

Department of Energy 

(DOE)

National Aeronautics and 

Space Administration (NASA)

National Institutes of Health 

(NIH)

National Science Foundation 

(NSF)

Budget management and financial reporting

Funding agency guidance waives prior approval requirements for many types of budget revisions. We examined the following 

examples of budget revisions for which agencies’ prior approval requirements vary: awarding fixed amount subawards; direct charging 

clerical and administrative salaries; and charging travel costs not previously included in research budgets.

Budget revisions for which 

DOE generally requires prior 

approval include: 

• travel costs not previously 

included in research 

budgete

Budget revisions for which 

DOE generally waives prior 

approval requirements 

include:

• awarding fixed amount 

subawards 

• direct charging clerical 

and administrative 

salaries 

Budget revisions for which NASA 

generally requires prior approval 

include: 

• awarding fixed amount 

subawards 

• direct charging clerical and 

administrative salaries 

• travel costs not previously 

included in research budget 

NASA does not waive prior 

approvals for any of these 

examples of budget revisions.

NIH does not require prior 

approvals for any of the 

examples of budget revisions 

we examined.f

 

Budget revisions for which NIH 

generally waives prior approval 

requirements include:f

• awarding fixed amount 

subawards

• direct charging clerical and 

administrative salaries

• travel costs not previously 

included in research budget

Budget revisions for which NSF 

generally requires prior approval 

include: 

• awarding fixed amount 

subawards 

• direct charging clerical and 

administrative salaries

Budget revisions for which NSF 

generally waives prior approval 

requirements include:

• travel costs not previously 

included in research budgetg

Financial reporting system:

• Fed Connect

Financial reporting system:

• Payment Management 

Systemh

Financial reporting system:

• Payment Management 

Systemh

Financial reporting system:

• Award Cash Management 

$ervice

Final reporting deadline:

• within 90 days of the 

end of the period of 

performance

Final reporting deadline:

• within 90 days of the end of 

the period of performance

Final reporting deadline:

• within 120 days of the end 

of the period of 

performance 

Final reporting deadline:

• within 120 days of the end of 

the period of performance

Source: GAO analysis of research funding agency guidance. | GAO-16-573

a

In accordance with the Uniform Administrative Requirements, Cost Principles, and Audit 

Requirements for Federal Awards (Uniform Guidance), DOE is in the process of drafting a conflict of 

interest policy that applies to conflicts that might arise around how recipients expend award funds, 

such as when selecting a subrecipient or procuring goods and services.

b

HHS’s financial conflict of interest regulation applies to institutions that receive funding 

from agencies in HHS’s Public Health Service, including NIH. Each recipient institution 

must maintain an up-to-date, written, enforced policy on financial conflicts of interest that 

complies with the regulation. For the purposes of this report, we focused on NIH’s implementation 

of the HHS financial conflict of interest regulation and did not review implementation by other Public 

Health Service agencies. The regulation defines an investigator as the person responsible for the 

design, conduct, or reporting of research funded by NIH and other Public Health Service agencies. 

For the purposes of this report, we use the term researcher instead of investigator.

c

NSF requires grantee organizations employing more than 50 persons to have a disclosure policy that 

generally requires disclosure, reporting, and management of financial interests listed in this table.

d

These requirements are based on the biographical sketch template used by DOE’s Office of 

Science—which provided 67 percent of DOE’s funding for university research in fiscal year 2015. 

DOE does not have agency-wide requirements for applicants to use a specific biographical sketch.

e

In commenting on a draft of our report, DOE stated that, as a matter of practice, DOE’s Office of 

Science does not require prior approval for these travel costs.

f

NIH waives prior approval for budget revisions of direct cost items such as travel costs unless there 

is a change in scope. NIH waives prior approvals for fixed amount subawards, provided that the 
Appendix III: Examples of Differences in 

Selected Administrative Requirements across 

Agencies in GAO’s Review

Page 57 GAO-16-573 Federal Research Grants

subawards meet the requirements for fixed amount awards in 45 C.F.R. 75.201. In addition, NIH’s 

Streamlined Non-competing Awards Process grants have different prior approval rules.

g

NSF waives prior approval requirements for international travel not previously included in the 

research budget, but does not specify the prior approval requirements for domestic travel not 

previously included in the research budget.

h

NASA and NIH require recipients to submit the cash management transaction portion of the Federal 

Financial Report through the Payment Management System.
Appendix IV: Office of Management and 

Budget and Selected Research Funding 

Agency Efforts to Reduce Administrative 

Workload and Costs Related to Selected 

Requirements

Page 58 GAO-16-573 Federal Research Grants

Table 5 provides information on Office of Management and Budget 

(OMB) and selected funding agency efforts to standardize forms, 

systems, processes, and provisions related to our selected administrative 

requirements on research grants. The efforts listed in table 5 all share the 

goal of reducing universities’ and other grantees’ administrative workload 

and costs, according to agency officials and documents.

Table 5: Examples of OMB and Selected Research Funding Agency Efforts to Standardize Selected Administrative 

Requirements 

Effort Description

Outcomes and effects on administrative 

workload and costs

Grants.gov—a common website for 

universities and other grantees to find and 

apply to funding opportunities posted by 

federal agencies

OMB created Grants.gov in 2003 in part to 

simplify the grant application process. The 

website allows for common application 

forms and submission processes for 

research grants, including proposed 

budgets and other information required in 

grant applications.

We reported in 2013 that many users have 

said Grants.gov made it easier for 

applicants to search for and identify federal 

grant funding opportunities.a However, 

DOE, NASA, and NSF use agency-specific 

systems in addition to Grants.gov to 

receive or process applications. These 

systems can include different application 

forms and requirements. In addition, DOE, 

NASA, NIH and NSF use “back-end”

systems that process applications 

submitted through Grants.gov and that, in 

some cases, can reject applications that do 

not meet agency-specific requirements for 

formatting and content. University officials 

generally agreed that variation in 

application systems adds to administrative 

workload and costs for applying for grants.

OMB requirements for standard financial 

and performance reporting forms

In December 2013, OMB consolidated its 

grants management circulars into a single 

document, the Uniform Administrative 

Requirements, Cost Principles, and Audit 

Requirements for Federal Awards (Uniform 

Guidance).b The Uniform Guidance set 

standard requirements for financial 

management of federal awards, including 

that agencies require university grant 

recipients to use OMB-approved 

government-wide standard forms for 

reporting financial and performance 

information for active grants.

Consistent with the Uniform Guidance, 

DOE, NASA, NIH, and NSF require 

grantees to use standard forms, such as 

the Research Performance Progress 

Report, for reporting financial and 

performance information. The Uniform 

Guidance does not standardize all 

requirements related to the financial 

management of grants. For example, the 

four agencies vary in their forms and 

submission systems for pre-award budget 

proposals, their systems for financial 

reporting, and their requirements for 

recipients to obtain prior approval to make 

certain post-award changes to project 

budgets. 

Appendix IV: Office of Management and 

Budget and Selected Research Funding 

Agency Efforts to Reduce Administrative 

Workload and Costs Related to Selected 

Requirements
Appendix IV: Office of Management and 

Budget and Selected Research Funding 

Agency Efforts to Reduce Administrative 

Workload and Costs Related to Selected 

Requirements

Page 59 GAO-16-573 Federal Research Grants

Effort Description

Outcomes and effects on administrative 

workload and costs

Pilot program to develop a central system 

for financial reporting and consistent 

government-wide terms and definitions

The Digital Accountability and 

Transparency Act of 2014 directed OMB, 

among other things, to establish a pilot 

program to address unnecessary 

duplication in financial reporting and reduce 

compliance costs for recipients of federal 

awards. The pilot program is ongoing and 

includes testing approaches to (1) allow 

grant recipients to submit financial reports 

in one central system, rather than in 

multiple systems for different agencies, and 

(2) develop consistent government-wide 

financial terms and definitions to simplify 

recipient reporting and help agencies when 

creating information collection forms.

We testified in 2014 that the Digital 

Accountability and Transparency Act could 

help promote the creation of reliable and 

consistent agency information, including 

information about how research grant funds 

are spent.c In addition, we reported in April 

2016 that the portion of the pilot program 

focused on reducing grantee reporting 

burden is generally on track to meet the 

requirements of the act, and that OMB has 

made considerable progress designing an 

approach that will examine a variety of 

potential ways to simplify reporting for grant 

recipients.d

Standard administrative terms and 

conditions for research grants

In 2008, RBMe issued, and research 

funding agencies implemented, a standard 

core set of administrative terms and 

conditions on research and researchrelated awards. In 2014, RBM began 

working on a revised set of standard terms 

and conditions for grants subject to the 

Uniform Guidance. Both versions of the 

standard terms and conditions include 

standard provisions related to budget 

management, financial reporting, 

purchasing, and subrecipient monitoring. 

For example, the standard terms and 

conditions generally require recipients to 

provide financial and other reports for 

project closeout within 120 calendar days 

after the end date of the project’s period of 

performance. NIH and NSF led these 

efforts through RBM.

DOE, NASA, NIH, NSF, and eight other 

agencies adopted the 2008 standard terms 

and conditions. The Department of 

Defense—which, after NIH and NSF, 

provides the largest amount of federal 

funding for research to institutions of higher 

education—adopted the 2008 version of 

the standard terms and conditions but did 

not adopt the revised version.

According to officials who led the 

development of the standard terms and 

conditions, RBM permitted agency 

exceptions in order to gain broader agency 

participation. For example, some agencies 

allow grantees to charge travel costs that 

were not previously included in project 

budgets without obtaining prior agency 

approval, while other agencies require 

grantees to obtain prior approval.

Standard research progress report RBM issued the Research Performance 

Progress Report in 2010 to reduce 

recipients’ administrative workload and 

costs through standardization of the types 

of information required in interim 

performance reports. The report includes 

standard components and reporting 

categories, including a category for budget 

information. In 2015, RBM drafted a revised 

version of the report, which will be used for 

final reports as well as for interim reports.

OMB and OSTP issued a memorandum in 

2010 requiring agencies to use the 

Research Performance Progress Report, 

and OMB, in the Uniform Guidance, 

directed agencies to require recipients to 

use standard, OMB-approved data 

elements, such as those in that report, for 

collection of performance information.

RBM had not issued a final version of the 

report as of April 2016, so its effect on 

administrative workload and costs is not 

known. 
Appendix IV: Office of Management and 

Budget and Selected Research Funding 

Agency Efforts to Reduce Administrative 

Workload and Costs Related to Selected 

Requirements

Page 60 GAO-16-573 Federal Research Grants

Effort Description

Outcomes and effects on administrative 

workload and costs

Central electronic system for assembling 

biographical sketches

In 2013, under the leadership of RBM, 

seven research funding agencies including 

DOE, NIH, and NSF developed SciENcv. 

SciENcv is a central electronic system 

researchers can use to assemble 

information on professional qualifications to 

develop biographical sketches for research 

grant applications. 

SciENcv was initially designed to generate 

biographical sketches for NIH applications, 

and its developers plan for it to be 

expanded to generate biographical 

sketches for other agencies in the formats 

required by those agencies.

SciENcv does not include standardized 

formats or content for biographical 

sketches. In addition, it had not been 

adopted by agencies other than NIH and 

NSF as of April 2016.

Legend

DOE: Department of Energy

NASA: National Aeronautics and Space Administration

NIH: National Institutes of Health

NSF: National Science Foundation

OMB: Office of Management and Budget

OSTP: Office of Science and Technology Policy

RBM: Research Business Models working group

Source: GAO analysis of OMB, OSTP, and research funding agency guidance. | GAO-16-573

a

GAO, Grants Management: Improved Planning, Coordination, and Communication Needed to 

Strengthen Reform Efforts, GAO-13-383 (Washington, D.C.: May 23, 2013).

b

78 Fed. Reg. 78,590 (Dec. 26, 2013).

c

GAO, Federal Data Transparency: Effective Implementation of the DATA Act Would Help Address 

Government-wide Management Challenges and Improve Oversight, GAO-15-241T (Washington, 

D.C.: Dec. 3, 2014).

d

GAO, DATA Act: Section 5 Pilot Design Issues Need to Be Addressed to Meet Goal of Reducing 

Recipient Reporting Burden, GAO-16-438 (Washington, D.C.: Apr. 19, 2016).

e

RBM is an interagency working group within the National Science and Technology Council. This 

council, within OSTP, is the executive branch’s principal means for coordinating science and 

technology policy across the diverse entities that make up the federal research and development 

enterprise. RBM membership consists of officials from federal research funding agencies—including 

DOE, NASA, NIH, and NSF—as well as officials from OMB and OSTP.

Table 6 provides information on agency efforts to streamline selected preaward administrative requirements, in particular by postponing certain 

requirements until a preliminary decision has been made about the 

likelihood of a proposal being funded. The efforts listed in table 4 all share 

the goal of reducing applicants’ administrative workload and costs for 

developing proposals—particularly in cases where the chance of the 

proposal being funded is small.
Appendix IV: Office of Management and 

Budget and Selected Research Funding 

Agency Efforts to Reduce Administrative 

Workload and Costs Related to Selected 

Requirements

Page 61 GAO-16-573 Federal Research Grants

Table 6: Examples of Selected Research Funding Agency Efforts to Streamline Selected Pre-Award Administrative 

Requirements through Preliminary Proposals

Agency Effort

Outcomes and effects on administrative workload 

and costs

DOE DOE uses several types of preliminary proposals.a

Generally, DOE’s preliminary proposals require brief 

descriptions of proposed projects, including the technology 

they involve and their potential impact. They generally do 

not require detailed budgets, biographical sketches, or 

data management plans.

DOE reviewers assess the preliminary proposals, 

encourage a subset of applicants to submit full 

applications, and discourage others. 

DOE’s Office of Science used some form of 

preliminary proposals for about 85 percent of its 

research grant solicitations from fiscal years 2013 

through 2015. Most applicants submitting preliminary 

proposals during that time were invited to submit full 

proposals, according to estimates from DOE.

DOE’s Office of Energy Efficiency and Renewable 

Energy used preliminary proposals on nearly all of its 

competitive solicitations. In the past year, between 

one-half and three-quarters of applicants submitting 

such proposals were encouraged to submit full 

applications, according to estimates from DOE.

NASA NASA uses a two-step proposal process, under which 

applicants start by submitting short, step-1 proposals. The 

elements of step-1 proposals vary across research 

programs, but are generally limited to summaries of the 

proposed project’s goals and objectives and its 

methodology. Step-1 proposals do not include detailed 

budgets.

NASA evaluates step-1 proposals to decide whether to 

invite step-2 proposals. NASA’s decision on step-1 

proposals can be either (1) nonbinding, where a step-2 

proposal may be submitted even if the step-1 proposal 

resulted in the applicant being discouraged, or (2) binding, 

where a step-2 proposal cannot be submitted if it was not 

invited.

NASA began piloting the two-step proposal process in 

spring 2012, initially in one research program. 

According to officials, NASA has expanded the 

process to about half of the research portfolio in the 

directorate that provides over half of NASA’s total 

research funding for higher education institutions, as 

well as to some grants within another directorate.

NASA information on its pilot showed that the results 

of the two-step proposal process differed across its 

programs. For example, in one program, around half 

of applicants were discouraged from submitting step-2 

proposals. In another program, NASA discouraged 

about 7 percent of applicants from submitting step-2 

proposals. 

NIH NIH uses a “just-in-time” process, under which certain 

elements of an application are not required to be 

submitted until after the application has gone through 

initial peer review and has received a qualifying score from 

reviewers. Information NIH requests at the post-review 

just-in-time stage can include (1) information on plans for 

sharing genomic data and (2) information on non-NIH 

sources of applicant financial support, which NIH reviews 

for budgetary overlap with requested NIH funding. The 

just-in-time process does not delay requirements for 

application elements such as project budgets or 

biographical sketches.

According to officials, NIH uses the just-in-time 

process for most grant programs but NIH does not 

maintain data on what percentage of applications 

reach the just-in-time stage. Therefore, it is not known 

how many applicants did not qualify to submit just-intime materials. According to an internal NIH evaluation 

from May 2005, around three-quarters of researchers 

and administrative staff reported overall satisfaction 

with the just-in-time process.
Appendix IV: Office of Management and 

Budget and Selected Research Funding 

Agency Efforts to Reduce Administrative 

Workload and Costs Related to Selected 

Requirements

Page 62 GAO-16-573 Federal Research Grants

Agency Effort

Outcomes and effects on administrative workload 

and costs

NSF NSF uses several types of preliminary proposals, which 

generally contain an overview of the proposed research 

with sufficient detail to allow assessment of the major 

ideas and approaches to be used. NSF’s preliminary 

proposals typically include four-page project descriptions 

and a one-page description of project personnel, among 

other elements, but do not include budgets, budget 

justifications, data management plans, or postdoctoral 

mentoring plans.

In addition, in fiscal year 2016, some NSF research 

programs began a zero dollar budget pilot program, under 

which proposals require a basic justification of the overall 

resources necessary to complete the project, without 

itemized dollar amounts for each budget category. If a 

proposal is recommended for award, NSF will request a 

full budget and budget justification.

Some NSF preliminary proposal processes result in 

binding decisions as to whether applicants can submit full 

proposals, and others result in recommendations for 

applicants to submit or not submit full proposals.

According to NSF data, in fiscal year 2014, over 3,700 

of the approximately 4,900 applicants that submitted 

preliminary proposals were discouraged from 

submitting, or not invited to submit, full proposals. An 

internal evaluation by one NSF division found that 

preliminary proposals generally succeeded in reducing 

applicant workload, for example, by lessening the 

number of proposal pages being written by 

researchers and simplifying the documents required 

from university administrative offices.

Legend

DOE: Department of Energy

NASA: National Aeronautics and Space Administration

NIH: National Institutes of Health

NSF: National Science Foundation

Source: GAO analysis of research funding agency guidance. | GAO-16-573

Note: The agency efforts listed here involve postponing pre-award requirements until preliminary 

decisions about the likelihood of funding have been made. In addition to these efforts, agencies have 

made efforts to reduce pre-award administrative workload and costs by streamlining application 

instructions and formatting, or through the use of electronic application portals and other information 

technology systems. For example, NIH has an ongoing effort to enhance and streamline its 

processes for peer reviews of applications by, for example, shortening page limits and aligning 

application elements with review criteria. NIH also implemented an electronic web-based system that 

helps streamline the preparation and submission of applications through Grants.gov to NIH and other 

participating agencies.

a

DOE uses several terms to describe its different preliminary proposal processes, including concept 

papers, letters of intent, and pre-applications.

Table 7 provides information on OMB and agency efforts to reduce 

grantees’ administrative workload and costs related to selected 

requirements, by allowing them more flexibility in their grant management 

approaches.
Appendix IV: Office of Management and 

Budget and Selected Research Funding 

Agency Efforts to Reduce Administrative 

Workload and Costs Related to Selected 

Requirements

Page 63 GAO-16-573 Federal Research Grants

Table 7: Examples of OMB and Selected Research Funding Agency Efforts to Allow Grantees Flexibility Related to Selected 

Administrative Requirements

Effort Description

Outcomes and effects on administrative workload 

and costs

Expanded 

authorities

OMB revised its grants guidance in the 1990s to allow 

“expanded authorities” for grant recipients.a The 

expanded authorities allow funding agencies to waive 

requirements for grant recipients to obtain agencies’

prior written approval before making certain changes to 

project budgets, such as carrying forward unobligated 

balances to later funding periods.

Under RBM’s 2008 standard terms and conditions that 

implemented OMB’s grant management guidance in 

effect at that time, DOE, NASA, NIH, and NSF waived 

many cost-related prior approvals, with some exceptions, 

such as for specific grants or types of recipients. Agency 

officials said that under the revised standard research 

terms and conditions currently being developed, 

agencies will continue waiving many prior approval 

requirements.

Officials from agencies and universities we interviewed 

generally agreed that the expanded authorities reduced 

grantees’ administrative workload and costs associated 

with budget revisions.

Uniform 

Guidance 

changes and 

agency efforts to 

allow flexibility for 

documenting 

personnel 

expenses 

In the 2013 Uniform Administrative Requirements, Cost 

Principles, and Audit Requirements for Federal Awards

(Uniform Guidance),b OMB modified requirements for 

documenting personnel expenses to focus on 

recipients establishing a strong system of internal 

controls over salary and wage expenses, while allowing 

greater flexibility in the processes recipients use to 

meet the requirements.

In 2011, four universities, in coordination with the 

Federal Demonstration Partnership and research 

funding agencies, began piloting a new method for 

documenting salary and wage charges to federal 

awards, known as payroll certification.c The objectives 

of the pilot were to achieve more efficiency and 

effectiveness in the management of salaries and wages 

charged to federal awards, compared to the widelyused effort reporting method outlined in OMB’s grants 

guidance at the time, and to better ensure that salary 

and wage expenditures are appropriately charged to 

federal awards. OMB and the offices of inspector 

general at NSF and HHS agreed that the pilot would 

include subsequent audits by the offices of inspector 

general to evaluate the results.

As of April 2016, the HHS and NSF offices of inspector 

general had issued audit reports for three of the four 

universities in the payroll certification pilot. Two of the 

reports found that the universities’ implementation of 

payroll certification did not weaken accountability over 

federal funds for salaries and wages. The third report 

was inconclusive on this issue because the auditors 

could not reconcile certain university accounting records. 

The HHS Office of Inspector General had not issued the 

fourth university’s audit report as of April 2016.

Officials from the two pilot universities said that the pilot 

resulted in reductions of over 80 percent in the number of 

forms that needed to be reviewed by principal 

investigators for oversight of salary and wage charges on 

their grants, and corresponding reductions in time 

needed to develop and process these forms. The officials 

also said the time and costs of training staff were lower 

under the pilot, because fewer people were responsible 

for certifications, and the concept of payroll certification is 

easier to understand than effort reporting. In addition, 

officials from these universities told us that payroll 

certification led to stronger internal controls, because 

researchers and administrative staff have a better 

understanding of the salary and wage charges they are 

certifying than they did with effort reporting. 
Appendix IV: Office of Management and 

Budget and Selected Research Funding 

Agency Efforts to Reduce Administrative 

Workload and Costs Related to Selected 

Requirements

Page 64 GAO-16-573 Federal Research Grants

Effort Description

Outcomes and effects on administrative workload 

and costs

Uniform 

Guidance 

provisions for 

fixed amount 

awards

In the Uniform Guidance, OMB added provisions 

specifically allowing the use of fixed amount awards—

grant agreements for which accountability is based 

primarily on performance and results rather than 

accounting for incurred costs. For example, award 

payments are based on meeting specific performance 

requirements of the award, and there is no agency 

review of the actual costs incurred. Awarding agencies 

or pass-through entities may use fixed amount awards 

if the project scope is specific and adequate data on 

cost or pricing are available.

OMB staff said that fixed amount awards can reduce 

some administrative burden and recordkeeping 

requirements, such as submission of invoices by the 

fixed amount award recipient. Agencies allowed fixed 

amount awards under certain circumstances prior to the 

Uniform Guidance, and OMB did not provide specific 

evidence to support that these reforms reduced 

administrative workload and costs. In addition, we did not 

specifically discuss the reforms with universities, so we 

do not know to what extent universities believe the 

reforms reduced their administrative workload and costs.

Uniform 

Guidance 

clarifications for 

direct charging of 

administrative 

support costs

In the Uniform Guidance, OMB clarified its prior 

guidance by detailing the conditions under which 

grantees may directly charge administrative support 

costs to grants—rather than being reimbursed for these 

costs as part of their indirect (or overhead) costs.

OMB staff said that this change reduced administrative 

workload and costs by better allowing universities to 

assign administrative staff to a specific research project, 

which in turn will allow researchers to focus more of their 

time on the scientific aspects of the project. Agencies 

allowed direct charging of administrative support costs 

under certain circumstances prior to the Uniform 

Guidance, and OMB did not provide specific evidence to 

support that these reforms reduced administrative 

workload and costs. 

NIH modular 

budgets 

In 1999, NIH implemented modular budgets as part of a 

streamlining initiative designed to focus the attention of 

researchers and NIH staff on science rather than 

budget details. Modular budgets generally apply to all 

NIH research grant applications requesting up to 

$250,000 per year, and allow recipients to (1) request 

budgets in “modules” of $25,000 and (2) decide after 

receiving an award whether to establish detailed 

budgets or to continue budgeting in $25,000 modules. 

Under modular budgets, applicants must provide 

budget narratives to support the personnel who will be 

working on the grant, but applicants generally do not 

need to provide narratives to support budget line items 

as they would with non-modular budgets.

According to a 2005 NIH evaluation, most principal 

investigators and other institutional officials surveyed 

reported that they were satisfied overall with the modular 

grant application process. The NIH evaluation and 

officials from four of the universities in our review also 

noted limitations in the workload reductions resulting 

from modular grant applications, such as when 

universities require principal investigators to submit a 

detailed budget to university administrators even though 

NIH does not.

NIH streamlined 

process for 

annual award 

monitoring

In 1994, NIH implemented an award process with a 

number of provisions for streamlined award 

negotiations, annual progress reports, and financial 

reports. Under the process, the NIH awarding officer 

negotiates direct costs for the entire project period at 

the time of the award, thereby eliminating the need for 

annual budget submissions and negotiations and 

reducing the information NIH requires to review, 

approve, and monitor awards for subsequent project 

periods. 

NIH routinely uses the streamlined award process for 

awards that make up around three-quarters of NIH 

funding for research grants, although specific awards 

may be excluded from the streamlined process under 

certain conditions, such as awards to high-risk recipients.

NIH officials said that the streamlined process allows 

grantees to focus more on the scientific aspects of their 

work and be less burdened with administrative 

processes.

Legend

DOE: Department of Energy

HHS: Department of Health and Human Services

NASA: National Aeronautics and Space Administration

NIH: National Institutes of Health

NSF: National Science Foundation
Appendix IV: Office of Management and 

Budget and Selected Research Funding 

Agency Efforts to Reduce Administrative 

Workload and Costs Related to Selected 

Requirements

Page 65 GAO-16-573 Federal Research Grants

OMB: Office of Management and Budget

RBM: Research Business Models working group

Source: GAO analysis of OMB and research funding agency guidance. | GAO-16-573

a

Office of Management and Budget, Uniform Administrative Requirements for Grants and 

Agreements with Institutions of Higher Education, Hospitals and Other Nonprofit Organizations, OMB 

Circular No. A-110 (1999).

b

78 Fed. Reg. 78,590 (Dec. 26, 2013).

c

This pilot was proposed and initiated by the Federal Demonstration Partnership—a cooperative 

initiative of 10 federal agencies and 155 institutional recipients of federal funds, with the purpose of 

reducing the administrative burdens associated with research grants and contracts. Prior to the pilot, 

the four universities employed the widespread practice of using effort reports as the main support for 

salary and wage charges to federal grants and contracts. Effort reporting is a person-based 

methodology that allocates each individual’s salary to the various projects worked on during the 

reporting period. In contrast, payroll certification is a project-based methodology that relies on a 

project’s principal investigator to certify that all salaries charged to the project are fair and reasonable 

in relation to the work performed. The Federal Demonstration Partnership asserted that payroll 

certification is preferable to effort reporting because (1) effort is difficult to measure and therefore 

effort reports provide limited internal control and (2) effort reporting systems can be expensive to 

implement and maintain.
Appendix V: Comments from the Department 

of Energy

Page 66 GAO-16-573 Federal Research Grants

Appendix V: Comments from the Department 

of Energy
Appendix V: Comments from the Department 

of Energy

Page 67 GAO-16-573 Federal Research Grants
Appendix VI: Comments from the Department 

of Health and Human Services

Page 68 GAO-16-573 Federal Research Grants

Appendix VI: Comments from the 

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

of Health and Human Services

Page 69 GAO-16-573 Federal Research Grants
Appendix VI: Comments from the Department 

of Health and Human Services

Page 70 GAO-16-573 Federal Research Grants
Appendix VI: Comments from the Department 

of Health and Human Services

Page 71 GAO-16-573 Federal Research Grants
Appendix VII: Comments from the National 

Aeronautics and Space Administration

Page 72 GAO-16-573 Federal Research Grants

Appendix VII: Comments from the National 

Aeronautics and Space Administration
Appendix VII: Comments from the National 

Aeronautics and Space Administration

Page 73 GAO-16-573 Federal Research Grants
Appendix VIII: GAO Contact and Staff 

Acknowledgments

Page 74 GAO-16-573 Federal Research Grants

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

In addition to the contact named above, Joseph Cook (Assistant Director), 

Ellen Fried, Cindy Gilbert, Elizabeth Hartjes, Terrance Horner, Miles 

Ingram, Richard Johnson, Sarah Martin, Dan Royer, and Monica Savoy 

made key contributions to this report.

Appendix VIII: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(361628)
Appendix VIII: GAO Contact and Staff 

Acknowledgments

Page 75 GAO-16-573 Federal Research Grants

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