Research Organizations Blast DOE’s Onerous Award Requirements

July 26, 2017 | By Jerry Ashworth | Post a Comment

energySeveral organizations representing research universities expressed frustration with the Department of Energy’s (DOE) onerous requirements placed on federal awards to research institutions. Earlier this month, the Association of American Universities, Association of Public and Land-Grant Universities and the Council on Governmental Relations sent a letter to the DOE Office of General Counsel, offering recommendations for numerous issues related to DOE-sponsored research that they believe are overly burdensome and need reform.

In the area of human subjects research, for example, the associations said that DOE has adopted the governmentwide Federal Policy for the Protection of Human Subjects, also known as the Common Rule, but has added additional requirements that increase regulatory burden without necessarily increasing participant protections. They encouraged DOE to eliminate the following:

  • with respect to research involving intentional modification of the human environment, special review requirements and the letter from the institutional review board (IRB) chair to the researcher indicating that the research has been approved in accordance with DOE expectations;
  • for research that involves personally identifiable information (PII), the DOE Checklist for Researchers Conducting Human Subjects Research that Utilizes PII, and IRB verification of compliance with those requirements in its review of the project in accordance with the DOE IRB Template for Reviewing Human Subjects Research Protocols that Utilize PII;
  • notifications to the DOE human subjects protection manager of significant adverse events, unanticipated problems or complaints about the research, study suspensions or terminations, or significant noncompliance; and
  • the requirement for periodic self-assessments by DOE contractors with respect to compliance with DOE Human Subjects Protection Program requirements.

Addressing another topic, closeout, the associations noted that closeouts of DOE awards to research institutions are subject to standard audit. However, after the standard audit, it then moves through a series of additional audits with no discernible order or checklist, including finance, property and disposition. The associations wrote that a research administrator at one major research university has spent two years trying to close out an outstanding invoice, and that during that time, the administrator has provided duplicate information on a number of occasions for new sets of auditors, and was told that there were 10 departments that handle closeouts so it was difficult to know the status of the audit. The associations recommended that DOE use a standard checklist for audits and develop a system that allows transparency for auditees.

The associations also said that there was a significant lack of consistency in reporting requirements across offices within DOE, adding that reporting frequency (quarterly vs. annual) and submission (web-based vs. emailed) varies and individual award documents are not specific about the requirements. They recommended that DOE implement consistent reporting requirements across offices and to make requirements clear in award documents.

The letter also addressed several other topics such as budget and budget justification requirements, solicitation requirements, user agreements, invoicing, drawdown disruptions and subaward agreements. Whether DOE amends any of its requirements remains to be seen, but presenting a united front is a good start for these research institutions weary of these often-onerous requirements. The ball is now in DOE’s court.

Let us know what you think about this letter to DOE and if you concur with the association’s concerns. We’d love to hear from you.

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