April 2, 1998
Transmitted by fax: (202) 401-7752
Ms. Suzanne Plimpton
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
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:
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.
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 <firstname.lastname@example.org>. Good luck with your
Ellen Reinsch Friese