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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