Transmitted by fax: (202) 401-7752

Ms. Suzanne Plimpton
USDA-CSREES
STOP 2299
1400 Independence Avenue, S.W.
Washington, D.C. 20250-2299

Reference: Uniform Federal Assistance Practices

Dear Ms. Plimpton:

On behalf of Wright State University, we are pleased to respond to the request for comments solicited by the Cooperative State Research, Education, and Extension Service (CSREES) as the agency strives to streamline its Federal assistance programs. The proposed changes to the draft documents recently distributed to State Partners for review will be welcomed by research administration offices in institutions of higher education. The comments address each set of draft documents individually.

1. General Terms and Conditions

The shift of responsibility for approval of pre-award costs, no-cost extensions, carry forward, and allowable budget changes from the CSREES to the awardee is a natural outgrowth of the successful Federal Demonstration Partnership. This move should lift a significant administrative burden from the CSREES, while allowing Authorized Organizational Officers (AOR) at awardee institutions the autonomy to manage budgets with a minimum of disturbance. It will provide an opportunity for awardees to respond to the needs of Principal Investigators/Project Directors on a timely basis and ultimately speed the process of research. The new responsibilities are also in line with the requirements of the National Institutes of Health and National Science Foundation, which will provide consistency in the administration of awards from all of these sponsors. Our institution is ready to take on these responsibilities.

It is also understood that those requested changes, outlined in Article 3., "Prior Approval Requirements," will still require the input of the CSREES Authorized Departmental Officer (ADO). We understand the need to coordinate requests of this nature with the CSREES and the Principal Investigator/Project Director, as the impact of a change in scope or key personnel may carry the research project far from its original intent.

2. Application Forms for Research and Extension Programs

The entire forms package should be made available on a Web site, where research administrators can download them and complete them on screen. Converting the forms to a PDF format would not be sufficient. The fields must be entered on the forms so that they can be completed on the computer screen. I would be happy to volunteer my expertise for this project, should it be necessary.

The following comments apply only to the CSREES-2003 "Budget" form:

• The form does not take into consideration the usefulness of an individual breakdown of time and compensation, should there be more than one investigator on a project. Additional lines for Co-PI(s)/PD(s) in Section A.1. should be added.
• For clarification, add "Including Canada, Mexico, and U.S. Possessions" to the "Travel" line item, F.1.
• The category for "All Other Direct Costs" (line I.) is a catch-all for a number of anticipated costs. There is no specific line item for Subcontracts or Consultant Services, and the CSREES must rely on the budget narrative to delineate these costs.

Move line item H. "Computer (ADPE) Costs" to the "Other" category and establish a classification for Subcontracts or Consultant Services. The importance of these line items is underscored by the amount of documentation required when including these categories in the request. In fact, funds for Consultant Services will be withheld unless and until the detailed information is submitted to CSREES.

• The purpose of line O., "Carryover," is nebulous. Obviously this line would not be used for new applications, and would it really be beneficial to use valuable space on this "Budget" form simply to provide an estimate of carryover funds? A much more accurate figure could be obtained from the financial report required of the awardee institution.
• The columns for cost sharing are taking up valuable space on the "Budget" form. If cost sharing is not a routine requirement for grant submissions, those columns could be eliminated. Line O. on the previous version of the Form CSREES-55 (6/95) which asked only for a cost-share dollar amount and details, if cost sharing were required, would be sufficient for the updated CSREES-2003.

3. Budget Documentation Requirements

An integral part of the proposal preparation exercise is the composition of the budget justification. This activity gives Principal Investigators/Project Directors the opportunity to rethink the research plans in terms of monetary impact. It is a very important part of the process, and the requirements of CSREES for documentation of costs are certainly reasonable in light of the ramifications of the partnership between the sponsor and the awardee.

Thank you for the opportunity to comment on the draft documents. If I can provide further clarification, please contact me at Wright State University at (937) 775-2425 or by e-mail at <efriese@wright.edu>. Good luck with your streamlining efforts.

Sincerely,

Ellen Reinsch Friese
Assistant Director