AAU, COGR and APLU recommend that OMB require Federal agencies to adopt common research terms and conditions. We believe NSF, NIH, USDA NIFA, NIST, NOAA, DOE, FAA, EPA and NASA are creating common RTCs, but other agencies have opted out. Clear and consistent data definitions are also needed.
Not all federal agencies are signing on to federal-wide research terms and conditions for federal awards under the Uniform Guidance as they had for A-110. This will result in less harmonization and greater agency deviation and will increase administrative burden as institutions are forced to comply with an array of different terms and conditions across multiple funding agencies.
We also wish to note that the continued delay in releasing the RTCs has real cost implications for institutions. As an example, because institutions do not know whether the RTCs will give them prior approval to manage and approve clerical and administrative costs after-the-fact some institutions are changing their technology. If, once the RTCs are released, they do have this authority, they will have wasted a lot of time and resources as a result of the delay.
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