AAU, COGR, and APLU recommend that OMB and federal research funding agencies and/or cognizant agencies work with the research community to explore the optional use of alternatives to measures of time as a means of assessing proper use of federal funds (e.g., information provided in progress reports and publications as an alternative to documenting personnel charges) as well as means of reducing reporting requirements. Mechanisms proposed in the Uniform Guidance that merit further discussion include:
• [200.430(i)(6)] - Cognizant agencies for indirect costs are encouraged to approve alternative proposals based on outcomes and milestones for program performance where these are clearly documented. Where approved by the Federal cognizant agency for indirect costs, these plans are acceptable as an alternative to the requirements of paragraph (i)(1) of this section.
• [200.430(i)(7)] - For Federal awards of similar purpose activity or instances of approved blended funding, a non-Federal entity may submit performance plans that incorporate funds from multiple Federal awards and account for their combined use based on performance-oriented metrics.
• Fixed amount awards [200.45; 200.201] - A type of grant agreement under which the Federal awarding agency or pass-through entity provides a specific level of support without regard to actual costs incurred under the Federal award. Accountability is based primarily on performance and results.
These efforts must differentiate scientific research grants from contracts and identify appropriate accountability measures in support of advancing specific and well defined agency research objectives. They could be piloted under the DATA Act pilot.