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February 28, 2005
Beth Phillips
Office of Federal Financial Management
Office of Management and Budget
725 17th Street, NW
Washington, DC 20503
Re: Proposed Policy on Terms and Conditions for Grants under Federal
Research and Research-Related Programs
Dear Ms. Phillips:
This statement from the Association of Independent Research Institutes
(AIRI) supports the Office of Science and Technology Policy (OSTP) and
Office of Management and Budget (OMB) proposed policy that would provide
guidance for streamlining terms and conditions for research awards across
all Federal research agencies. We acknowledge the extensive outreach to the
public and the Federal agencies that identified key policy implications of
Federal support for 21st century scientific research.
The Association of Independent Research Institutes is a nationwide
association of 89 non-profit independent research institutes conducting
peer-reviewed basic and applied research in the biomedical and behavioral
sciences. AIRI institutions are distinct from other organizations involved
in research -- such as universities, hospitals, and for-profit organizations
-- in their organization, mission, and size. Their flexibility provides an
environment that is particularly conducive to creativity and innovation in
research. Independent research institutes receive 11% of NIH extramural
research grant funding. Other AIRI Federal funding sources include the
National Science Foundation, the Department of Energy, the Department of
Defense, the Department of Agriculture, the Centers for Disease Control and
Prevention, and the Department of Education.
Through participating in the Federal Demonstration Partnership (FDP) and
attending key National Science and Technology Council (NSTC) workshops, AIRI
member institutes have offered support for the Council’s Subcommittee on
Research Business Models (RBM) in its effort to review policies, procedures
and plans related to the business relationship between Federal agencies and
research performers.
AIRI affirms OSTP and OMB’s efforts in formulating core principles and a
streamlined policy approach for Federal research and research-related
grants. The framework is based on sound analyses and provides a solid basis
for applying the FDP terms and conditions to all academic and nonprofit
grantees. In the spirit of acknowledging the intense effort that led to this
policy, AIRI reaffirms a strong commitment to the core set of terms and
conditions as being broadly applicable to all Federal agencies that issue
research and research-related grants.
As the proposed policy is implemented, a further definition of “research”
and “research-related” will be essential to assure that the terms and
conditions are applied consistently across agencies. AIRI encourages and
supports OSTP and OMB in efforts to assure that all Federal agencies adhere
to the standard terms and conditions, and that deviation will be only for
exceptional and rare circumstances. Consistency across agencies will be an
essential feature of successful policy implementation. AIRI is confident
that OSTP and OMB will develop an approach to assure that any grandfathered
exceptions and any new exceptions will be examined in an interagency
context, in accord with the spirit and core principles of the FDP.
AIRI believes that the issuance of a new policy on terms and conditions for
grants under Federal research and research-related programs, as proposed,
creates a reinvigorated context for agencies and grantee institutions to
demonstrate the highest standards for stewardship of Federal funds and
efficient, effective administrative processes.
AIRI thanks you for the opportunity to provide comments, and looks forward
to offering support as the initiatives move ahead.
Sincerely,
Randall C. Main
AIRI President
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