AAU-APLU Response 4/30/2012 AAU Association of American Universities APLU Association of Public and Land-grant Universities Association of American Universities •1200 New York Ave., NW, Suite 550, Washington, DC 20005 •(202) 408-7500 Association of Public and Land-grant Universities • 1307 New York Ave., NW, Washington

 A group of four associations, including AAU, sent a letter to White House Office of Management and Budget (OMB) Controller Daniel Werfel on March 7 requesting a 30-day extension of the comment period on OMB’s request for comments on its Advanced Notice of Proposed Guidance (ANPG) on grant reform.

The Association of American Universities (AAU) and the Association of Public and Land-grant Universities (APLU) welcome the opportunity to respond to the National Institutes of Health (NIH) June 28, 2011 Request for Information (RFI): Input on Reduction of Cost and Burden Associated with Federal Cost Principles for Educational Institutions (OMB Circular A-21) (NOT-OD-11-091). Together, AAU and APLU represent most of the nation’s large public and private research universities. Research universities strongly support the objectives of accountability and transparency, and our member institutions firmly believe that compliance and regulatory oversight are essential to the conduct of federally-supported research.

The Interagency Task Force’s efforts to reform OMB Circular A-21 and the Administration’s other efforts on reducing regulatory burden are of critical importance to our member institutions.

Improved alignment of cost principles and regulatory policies is essential to the health of the university-government research partnership and to the efficient and productive use of federal research funding. Given increasing fiscal constraints facing our universities, it is imperative that we work to ensure efficiency in government regulation to reduce the costs of compliance and to maximize the productivity of researchers.

 An AAU, APLU, and COGR report submitted to the National Research Council panel that is studying the future of the research university which lays out recommendations for reforming regulatory and compliance costs of university-based research. 

Dear Ms. Rockey: We write on behalf of the Association of American Universities (AAU) and the Association of Public and Land-grant Universities (APLU) to express concerns about changes recently announced by the National Institutes of Health (NIH) concerning its treatment of facilities and administrative (F&A) expenses pertaining to genomic arrays supported by NIH-funded programs (Budgeting for Genomic Arrays for NIH Grants, Cooperative Agreements and Contracts – Notice Number: NOT-OD-10-097, May 13, 2010). We agree in principle that the treatment of research costs might change periodically consistent with advances in scientific
methods and instrumentation. However, speaking for virtually every U.S. research university – with over 200 U.S. universities among our combined memberships – we are increasingly troubled by what we believe to be unbalanced cost burdens on universities that have accumulated over some 20 years as a result of what appear to
be similar arbitrary impositions by NIH and other agencies.

Dear Secretary Chu: On behalf of the Association of American Universities (AAU) and the Association of Public and Lang-grant Universities (A۰P۰L۰U), which together represent most major public and private U.S. research universities, we write to express our enthusiasm about the newly established Advanced Research Projects Agency for Energy (ARPA-E). This new agency within the Department of Energy (DOE) will provide university researchers with exciting new opportunities to engage in transformational research to address major energy challenges facing our nation and the world. AAU and A۰P۰L۰U stand ready to support this organization in any way we can to ensure its success. To this end, we have submitted over 50 names of faculty and other researchers from our campuses who have stepped forward to serve as program officers and assistant program officers in the new ARPA-E.

Dear Ms. Richards: On behalf of the Council on Governmental Relations (COGR), the Association of American Universities (AAU), and the National Association of State Universities and Land-Grant Colleges (NASULGC), please find attached our response to the August 6, 2008 Federal Register Notice request for comments on the use of cost sharing in National Science Foundation-funded activities.

The cap is unjustified for several reasons. Both direct and indirect costs are real costs of performing research that are distinguished only by the ability of an organization's accounting system to attribute each cost to a specific research project. An indirect cost is one that cannot be attributed to a specific project
because it supports the research enterprise as a whole or is a general cost of doing business. Absent evidence of systemic overcharging of the Government by research institutions (e.g., from their federally required financial audits), there is no rational basis to question the legitimacy of the indirect costs charged to DoD basic research.

The FY2008 House Defense appropriations bill would severely limit the amount universities can be reimbursed for costs incurred while conducting Department of Defense basic research.

Dear Mr. Stern: As associations representing the nation’s research universities and their affiliated academic medical centers, teaching hospitals, research institutes, and research faculty and staff, we recommend that the Inspector General withdraw the proposed Compliance Program Guidance for Recipients of PHS Research Awards in its current form. The detailed description of the compliance program and discussion of compliance risk areas will not accomplish the objective of enhancing compliance. It is too limited in scope and focus to result in the most effective compliance approaches. PHS research awardees share the belief that an effective compliance program helps ensure good stewardship of Federal funds. They are already striving to meet the goals of improving grants management and ensuring responsible conduct based on guidance developed by the research community itself, tailored to meet the complex compliance challenges inherent in the research enterprise.

Dear Subcommittee Members: On behalf of the Association of American Universities (AAU) and the National Association of State Universities and Land-Grant Colleges (NASULGC), we write in response to the request for comments from the National Science and Technology Council (NSTC) published in the Federal Register on August 6, 2003. This notice requested input from stakeholders to assist the NSTC Subcommittee on Research Business Models in its current review of policies affecting the "business relationship" between federal agencies and research performers.

To Members of the Subcommittee: We are writing as members of a subcommittee of the Association of American Universities, which represents 60 leading public and private research universities in the US. Our subcommittee concerns OMB Circular A-21, and we wish to respond to your August 6 Federal Register notice soliciting information for your examination of “the business relationship between federal agencies and research performers with the goal of improving the performance and management of federally sponsored basic and applied scientific and engineering research.”

Dear Dr. Holland: The Association of American Medical Colleges (AAMC) appreciates this opportunity to submit comments to the National Science and Technology Council on its review of “business models” supporting research between federal agencies and academic and other non-governmental institutions.

Dear Mr. Tran: We write on behalf of the Association of American Universities and the National Association of State Universities and Land-Grant Colleges to express our concern over OMB's proposed changes to Circular A-21 as part of OMB's effort to simplify the cost principles in that circular and two others (A-87 and A-122), and to make the descriptions of similar cost items consistent with one another where possible.

Dear Rita, AAU member institutions value the long-standing partnership between research universities and the federal government. This partnership has produced tremendous benefits for the American public. It has resulted in the generation of new knowledge and discoveries that have improved the public health, raised Americans’ standard of living, and created jobs. An important aspect of the partnership is the shared responsibility for supporting the costs of university infrastructure associated with federally sponsored research. The process established to allocate these costs fairly is the facilities and administrative (F&A) rate mechanism. When universities do not recover from the federal sponsor a fair share of F&A expenses attributable to the research, they must pay for them by taking resources away from other research and education obligations.