ABOUT THE COHORT
The Cohort for Efficiencies in Research Administration (CERA) seeks to establish industry standards for institutions to effectively and efficiently implement and comply with the regulations that govern sponsored research. The standards are developed to achieve compliance not exceed it and built through the development of model policies, procedures, and practices designed to reduce administrative burden for both faculty and the institution, minimize audit risk, and most importantly, facilitate research within an ethical and appropriate compliance framework. The standards are validated by their promulgation among institutions and tested or reviewed by members of the audit community.
CERA is Co-Directed by Lisa Mosley, Executive Director of Sponsored Programs, Yale University, Jeremy Forsberg, Assistant Vice President for Research, The University of Texas at Arlington, and , David Ngo, Assistant Vice President, New York University. For more information about CERA, please contact one of these team members.
PUBLISHED STUDIES ON ADMINISTRATIVE & FACULTY BURDEN
"Institutions must carefully consider the appropriate balance between controls and risk in their grant award programs and operations. Too many controls can result in inefficient and ineffective operations; institutions must ensure an appropriate balance between the strength of controls and the relative risk associated with particular grant award programs and operations. Additionally, the benefits of controls should outweigh the costs.Institutions should consider both qualitative and quantitative factors when analyzing costs against benefits."- 2 CFR Part 200, Appendix XI, Compliance Supplement Part 6
2012 Federal Demonstration Partnership
2012 Faculty Workload Survey' Research Report
“The most commonly experienced administrative responsibilities (of 23) included those related to Federal project finances, personnel, and effort reporting. These were also among the most time-consuming responsibilities.”
2005 and 1012 Faculty Workload Surveys found that federally funded PIs spend 42% of their research time on administrative tasks.
82% recognized effort reporting as taking time away from research and nearly 50% identified it as taking a substantial amount of their time.
Most common uncertainties in accounting for effort involved time spent: brainstorming and reading, working over 40 hours a week, working on multiple projects, the intermingled nature of their activities, and discerning actual hours vs. percentages. The requirements were noted to be unclear, specifics unnecessary, and definitions too rigid.
2014 National Science Board
Reducing Investigators’ Workload for Federally Funded Research
A culture of over regulation has emerged due to a perceived increase in auditing practices and resulting institutional concerns for liability.
“a substantial lack of consistency and standardization remains within and among agencies in all aspects of grant management”
“…avoid adding unnecessary requirements to those already mandated…”
“Dissemination of effective practices and models can create efficiencies that reduce PIs’ administrative workload.”
Time and effort reporting is ambiguous, time consuming, and not an effective measure of proper use of Federal funds. It is incongruent with the administrative structure of universities and the actual manner in which faculty perform research, which is difficult to track given their simultaneous work on multiple projects and the degree to which activities are interwoven.
2016 National Academy of Sciences
Optimizing the Nation’s Investment in Academic Research
“When regulations are inconsistent, duplicative, or unclear, universities may place additional requirements on research investigators, thereby diminishing the effectiveness of the national investment in research.”
“Academic research institutions may be audited by an agency’s Office of Inspector General, many of which have very different approaches that in some cases are incongruent with stated policies of their agency.”
Recommend inspectors general to 1) Resolve policy interpretation issues with their agencies before conducting formal audits, 2) Include examples of effective, innovative, and cost-saving initiatives of institutions that advance and protect research, and 3) Only publicly report final audit resolution findings.
Recommend Institutions to 1) review and assess their policies and processes to ensure they are not excessive or create unnecessary self-imposed burden and 2) revise policies that go beyond those necessary and sufficient to comply.
Recommend OMB to affirm institutions can take advantage of UG flexibility for documenting personnel expenses.
There is no mechanism or process for stakeholders to consider the effectiveness of existing or new research policies necessary for an efficient and effective research enterprise. No entity exists to collect data that can measure the effectiveness and unintended consequence of research regulations.
Reducing Administrative Burden in Federal Research Grants to Universities
This report analyzes the regulatory and policy requirements that govern the management of federal funds invested in research at universities and the inefficiencies often generated in the form of administrative burden and cost. It examines this complex ecosystem of multiple stakeholders from the perspective of the grant recipient.
The authors focus on the financial and programmatic compliance requirements of managing grants at universities, with the understanding that at a foundational level, the ethical conduct and integrity of conducting research is critical to the success of the U.S. federal government’s $40 billion annual research and development investment with universities. However, the emphasis on procedural accountability is increasingly undermining the ability of academic researchers to focus their attention on conducting the research itself. The authors report that researchers spend 44 percent of their research time complying with administrative requirements, many of which derive from federal mandates.
This report draws from the three authors’ multiple decades of experience managing federally funded projects, implementing university policies and procedures to comply with federal regulations, overseeing federal audit engagements, and participating in various professional organizations in an attempt to reduce regulatory burden and promote efficient practices.
Expectations and benefits of participation:
It is expected that Cohort members will actively engage and participate effectively in the development of the cohort standards and related materials. Cohort members will maintain communication among each other through regularly scheduled meetings, conference calls and emails.
Cohort members recognize the results of cohort activities must be publishable. Any oral or written contributions to the Cohort Standards by Cohort members may be incorporated by the Project Team in any public presentation, website, or project deliverable at the Cohort Team’s discretion. Any contributions made in whole or in part by Cohort member and included in a project deliverable will be made freely available, with usual and customary attribution, but without compensation. The Cohort Team has the final authority to determine the scope and content of any published project deliverables.
As a benefit of participation, Cohort members will have the right to use, re‐publish and make derivatives of any combination of the project deliverables; however, any use will properly recognize the CERA Cohort, including any written use of materials or other public presentations or online publications.
Participation in the Cohort is completely voluntary and may be terminated at any time by submitting the request to the Cohort Team. Each Cohort member is responsible for its own expenses related to participation in the Cohort.
Each Cohort member will be asked to complete a survey related to the institutional cost savings and the reduction of faculty and administrative burden for adopting, implementing, or using Cohort related materials. Survey results and analysis will be available to all survey participants.
Sponsor a Cohort
Cohort Sponsors are valuable contributors helping to set the Industry Standards of a Cohort project. They provide support for the dissemination and targeted development of select Cohort materials.