Notice Number: NOT-OD-11-091

Key Dates
Release Date: June 28, 2011
Response Date: July 28, 2011

Issued by
National Institutes of Health (NIH)

Purpose

This Notice is a time-sensitive Request for Information (RFI) offering the opportunity for input on potential revisions to OMB Circular A-21, 2 CFR Part 220 (Cost Principles for Educational Institutions, accessible at http://www.whitehouse.gov/omb/circulars_a021_2004) that could reduce administrative burden or costs associated with compliance requirements for Federal research grants and contracts awarded to educational institutions. Any potential revisions must be consistent with responsible compliance and accountability.

Background

An interagency task force (A-21 Task Force) to consider potential revisions to OMB Circular A-21 has been established by the National Science and Technology Council (NSTC) Interagency Working Group on Research Business Models (RBM) under the Subcommittee on Social, Behavioral and Economic Sciences (SBE) of the Committee on Science (CoS). The Task Force includes representatives from the Department of Agriculture, Department of Defense, Department of Energy, Department of Education, Department of Health and Human Services, National Aeronautics and Space Administration, National Science Foundation, National Institutes of Health, and the Executive Office of the President including the Office of Management and Budget and the Office of Science Technology Policy. The Task Force will review issues surrounding Circular A-21 with respect to its application to the conduct of Federally-sponsored research at educational institutions, including the consistency of application by Federal agencies, costs, and administrative burdens. The Task Force will recommend specific revisions and clarifications to Circular A-21 to the NSTC for review and transmission to OMB.

Preliminary information gathered by the Task Force, which includes Government Accountability Office reports and recent recommendations from associations, societies, and other organizations with an interest in Federal investments in research, have suggested that improvements in the following areas related to Circular A-21 could reduce the administrative and fiscal costs and burden associated with the conduct, management, and oversight of Federal research grants and contracts to educational institutions:

• Effort reporting,
• Recovery of direct costs associated with administrative and project management support for investigators,
• Institutional eligibility for the Utility Cost Adjustment,
• Consistency among agencies that establish government-wide Facilities and Administration (F&A) rates,
• Programs with F&A reimbursement at other than government-wide rates,
• Rationalization between agencies of regulations and reporting requirements (e.g. deemed exports, Institutional Review Boards, visas ),
• Audits of research institutions and awards, and
• Definitions of general and research equipment.

The Task Force will consider possible improvements in these and other areas as it conducts its review. Consideration of changes to the administrative costs cap of 26% or of compliance issues related to research conducted by other types of organizations (including non-profit institutions, hospitals, and for-profits) is beyond the scope of the Task Force.
Information Requested

To ensure a thorough and comprehensive evaluation of administrative and fiscal burdens associated with Federal research grants and contracts oversight, as well as to gather recommendations for revisions to the current OMB Circular A-21, responses are being sought from educational institutions and their staff and faculty and from the general public. Information is sought for each of the areas identified above and any other items the Task Force might consider for lowering the cost and burden of the application of Circular A-21.

1. For any of the areas identified above and any other specific areas of Circular A-21 you believe are worthy of consideration by the Task Force, please
   
   
   1. Identify the issues(s) and impact(s) on institutions, researchers, or both;
   2. Where possible quantify the impacts, e.g., in terms of cost to the institution or the estimated number of hours (or percentage of time) that researchers or compliance staff spend addressing the issue(s).
2. Please identify and explain which of the issues you identified are, in your opinion, the most important for the Federal Government to address. As a reminder, consideration of a change to the 26% administrative cap is beyond the scope of the Task Force.
   
3. You may also offer proposed wording changes to Circular A-21 or any other Federal Government policy issuance that you believe would best address an identified issue. Please be as specific as you can, e.g., if possible, provide a line-in and line-out markup of the pertinent paragraphs of the current language. Circular A-21 can be found at http://www.whitehouse.gov/omb/circulars_a021_2004 .

Response to this RFI is voluntary. Responders are free to address any or all the above items. Please note that the Government will not pay for response preparation or for the use of any information contained in the response. RBM will provide a summary of all input received which is responsive to this RFI by September, 2011.

How to Submit a Response

All comments must be submitted electronically to:

https://grants.nih.gov/grants/guide/rfi_files/a-21/add.htm

Responses to this RFI will be accepted through July 28, 2011. You will receive an electronic confirmation acknowledging receipt of your response, but will not receive individualized feedback on any suggestions. No basis for claims against the U.S. Government shall arise as a result of a response to this request for information or from the Government’s use of such information.

Inquiries

Specific questions about this RFI should be directed to the following e-mail address: A-21_Task_Force@mail.nih.gov