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Archived File. The file below has been archived for historical reference purposes only. The content and links are no longer maintained and may be outdated. See the OER Public Archive Home Page for more details about archived files. OSTP RBM Workshop on Cost Accountability.

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archived file

Archived File

The file below has been archived for historical reference purposes only. The content and links are no longer maintained and may be outdated. See the OER Public Archive Home Page for more details about archived files.

ostp rbm workshop on cost accountability

OSTP RBM Workshop onCost Accountability

University of North Carolina

November 17, 2003

Elizabeth Mora

Director, Office for Sponsored Research

Harvard University

main question universities ask
Main Question Universities Ask:
  • What happened to the Partnership?
  • Has it turned into a “Procurement Process”?
let s step back for a moment
Let’s Step Back for a Moment
  • OMB Circular A-21 was introduced in 1958
  • During the 1990’s, a time of mistrust,
    • An administrative cap was imposed (in 1991)
    • A-21 was changed five times. Each time, unfunded mandates were added with little attention to their cost or their added value for rational stewardship and accountability
it s time to re evaluate a 21
It’s time to re-evaluate A-21!
  • Was university abuse of regulations widespread?
  • Were the changes in A-21 the right “remedies”?
  • Can we work together to develop a more effective and efficient costing and regulatory system that appropriately reflects the diversity of research providers?
  • The principle of full cost reimbursement is vital.
  • Actions should not be taken unilaterally with little regard for their implications for the University community
  • Administrative compliance should be differentiated from scientific compliance
  • No serious attention is given to the radical changes in the costs of information acquisition and exchange produced by digital technology.
  • All issues are not equally important. Do the rules give the proper relative weight to
    • Human subject protection and payroll certification?
    • Assuring environmental health and safety and completing Disclosure Statements (that never get read or reviewed)?
    • Securing of biohazardous agents and providing lease-purchase analyses?
questions cont
Questions (cont)
  • Do the program sides of funding agencies communicate adequately with their Inspector Generals on the interpretation and the consequences of rule changes?
  • What happened to the operating principles proposed in the PRD-4?
potential solutions
Potential Solutions
  • Actively engage OMB in the dialog on the cap andA-21.
  • Actively use FDP as a working group
    • Some federal agencies are already engaged; engage others (including OMB).
    • Pursue pilot projects that have momentum, e.g.,subrecipient monitoring
    • Determine why agencies are dragging their feet on other proposed pilot projects
potential solutions cont
Potential Solutions (cont)
  • Solicit university participation on

PL 106-107 working groups

    • What are these groups doing?
    • What are the goals and the deliverables?
  • Bring funding agencies, the audit community and the university research community closer together to seek agreement on acceptable principles and processes
potential solutions cont1
Potential Solutions (cont)
  • Look at “best practices” across agencies and adopt these across all agencies


    • NSF clarification of cost sharing policy
    • NIH letter of credit system
potential solutions cont2
Potential Solutions (cont)
  • Work through FDP – Initiative to Reduce Administrative Burden on eliminating the non-value added unfunded mandates in A-21:
    • DS-2 requirement
    • Lease purchase analysis
    • Monthly cash flow for debt arrangements in excess of $1M
potential solutions cont3
Potential Solutions (cont)
  • Reasonableness cost of new construction
  • Requirement to use depreciation recoveries to acquire or improve research facilities
  • Requirement to demonstrate the reasonableness of  cost of construction for new research buildings

These are low hanging fruit!

Let’s pick them off!

potential solutions cont4
Potential Solutions (cont)
  • Get OMB and OSTP involved in other “bigger” administrative issues to find a simpler method:
    • Allocation of space costs
    • Effort reporting/payroll certification
    • Subrecipient Monitoring
    • A-133 audit requirements
    • Recognition of costs of digital information exchange