[Okgrantsmanship] COGR: Improving Circular A-21 and Reducing Burden

[Mason, Linda]

An OMB-lead "A-21 Task Force" was established several months ago and
COGR has been in regular contact with the Task Force. The A-21 Task
Force is co-chaired by three representatives - one each from OMB, NIH,
and DOD. In total, the Task Force has over ten members and represents
all the major research funding agencies. Our agenda is their agenda - in
other words, many of the recommendations COGR has made over the past six
months are items that the Task Force will address. The only item that
has been specified as not open for discussion is the 26-percent
administrative cap. Some of the issues that the Task Force plans to
address include: 

*	Reduce the Burden of Effort Reporting 
*	Allow Direct Charging of Research Administrative and Compliance
Support (i.e., F6b) 
*	Consistent Application of the 1.3% Utility Cost Adjustment 
*	Improve the F&A Rate-Setting Process 
*	Consistent Implementation of Circular A-21 Across Agencies
(e.g., Reimbursement of the negotiated F&A rate) 
*	Reduce the Burden of Subrecipient Monitoring 

A "Request for Information" (RFI) has been issued by the Task Force
(under the auspices of an NIH RFI). Responses to the RFI are due on
Thursday, July 28, 2011. We understand that the Task Force plans to
sponsor a "Town Hall" meeting prior to the RFI due date. This will
provide the broad community with an opportunity to engage the Task Force
in an open forum. The RFI can be accessed at:
 
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-11-091.html
 
A COGR workgroup including members from Costing Polices and RCA are
preparing responses. Our plan is to share a final draft with the
membership several days before the RFI due date. While our responses
will emphasize issues related to Circular A-21, we will call attention
to those topics that cross-cut with OMB Circular A-122 for Non-profit
Organizations and the Hospital Cost Principles. COGR members are
encouraged to provide institution-specific responses, and of course,
your institution is always welcome to endorse the COGR response. Also,
we will be strategizing with our association partners from the
Association of American Universities (AAU) and the Association of Public
and Land-grant Universities (APLU) to ensure we provide the most
comprehensive and robust response possible.
 
COGR is viewing this process as a realistic opportunity to develop new
solutions and models applicable to a wide-range of vexing research
financial and costing issues. We will provide regular updates to the
membership as this process unfolds. If you have comments or input or an
issue that you feel should be raised to the A-21 Task Force, please
contact David Kennedy at dkennedy at cogr.edu. 
 
David Kennedy
Director, Cost Policy
1200 New York Ave. NW, #750
Washington, DC  20005
(202) 289-6655, ext. 112
dkennedy at cogr.edu 

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