Duke University Response to OMB Circular A-21 Task Force

An important federal Task Force has been created by senior leadership at OMB, NIH, DoD, & NSF to develop recommendations for substantive changes in reduction of compliance requirements and funding formulas that may have significant positive impact on how federally funded research is conducted and managed.  Recipients of federal research funds have been invited to provide comments and recommendations in support of regulatory reduction and streamlining the research management process.  This is a unique and important opportunity to comment on how the current regulatory burden imposed by the (OMB) Circular A-21 poses challenges to the critical research contributions made by universities, and to offer suggestions for how this burden can be significantly mitigated.  Some of the topics specifically mentioned in recent discussions include:

  1. Reducing the burden of Effort Reporting
  2. Allowing direct charging of administrative support staff to federal grants (CAS)
  3. Reducing the burden of Subrecipient Monitoring
  4. Consistency of regulations across agencies and sponsors (export controls, FISMA, IRB, Visa)
  5. Definition and allowability of direct charging of general (computers) and research equipment

Duke University has issued a strong and positive response to this initiative.  The complete response package contained a cover letter from President Brodhead, an introductory letter from Drs. Trask, Lange, and Dzau, seven Faculty/Leadership letters, and a specific detailed response that addresses these issues.

It is possible that the joint task force will issue preliminary recommendations based on recipient feedback by the end of August.  I will keep the Duke University community advised as events unfold.

Request for Information (RFI):  NIH Website