Research administration in history: the development of OMB circular A-110 through Joseph Warner's COGR subcommittee, 1976-1979.

Author:Myers, Phillip E.
 
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The Warner Subcommittee

Administrators seldom ponder the origins of the documents they use to interpret principles. Research administration developed rapidly beginning in 1948 with the federal government's transition from purely military procurement to investment in academic research. The inauguration of COGR in 1960, along with the proliferation of research administration offices in the 1960s, the growth of federal funding in the era of the Cold War and Sputnik from $405 million in 1960 to $1.7 billion in 1970, made it imperative for research administrators to have a voice in the revision of A-110, the first codification of federal standards to federal granting agencies (Norris & Youngers, 2000). When Joseph Warner's subcommittee arrived on the scene, university central sponsored programs offices were proliferating, and feeling their way with a fierce desire for independence from the federal oversight that had been the norm in the 1960s (Warner, 2008; Norris & Youngers, 2000). They were swept into the issue of federal principles guiding federal agencies, which concerned A-110. This issue characterized the period from the mid-1970s to the late 1980s, which, as Norris and Youngers (2000) explain, "saw the greatest growth of regulation and compliance activity in the research enterprise." In this period the federal government began to play a direct role in assuring that universities fulfilled their responsibilities for handling federal funds, especially because of the phenomenal rate of growth from $2.5 billion in 1976 to $9 billion in 1989 (Norris & Youngers, 2000).

During this surge, the Warner subcommittee worked to assure that the federal principles governing the grants and contracts actions of federal sponsoring agencies were not intrusive and impractical compared to the needs of university research and research administration.

The subcommittee endeavored on behalf of 100 research universities to secure and maintain a positive relationship with the Office of Management and Budget (OMB), which was the link between the universities and the federal sponsors. The OMB knew that COGR was the primary communication link for revisions. COGR's role, then, was to develop a university consensus on the principles for revision and to suggest alternatives for resolutions. COGR's views prevailed most of the time (Warner, 2008).

This activity spanned the initial concern with financial research administration for policy design and proposal preparation. Mr. Warner, as Chair of the Subcommittee on Grant and Contract Provisions, often performed the initial analysis of the A-110 principles under revision. He then transmitted his draft to the subcommittee members. After they responded, Mr. Warner created a summary statement for Reagan Scurlock, the Executive Director of COGR. In this process, Mr. Warner observes that the subcommittee members from research universities brought a "keen understanding and empathy" to faculty research and a desire to protect academic freedom (Warner, 2008).

The pursuits of the Warner subcommittee confirm that research administration has developed quickly over the past 50 years, in response to the rapid development of research and supportive technology. Knowledge of the origins and revisions of federal principles that govern university-sponsor relationships helps with interpretation and confidence in doing business and in reorganizing research administration offices to better facilitate the needs of researchers (Norris & Youngers, 2000). The subcommittee's pursuits manifest the goal that COGR's mediating function has always been the education of federal sponsors about academic operations and unnecessary burdens (COGR, 2001).

For these reasons, it is instructive to show how Mr. Warner and his colleagues shaped many of the key principles in the 1970s and 1980s, when compliance became a large issue and experienced its greatest growth in the relations among research administration offices, campus structures and the federal government, which was composed of 18 grant-awarding departments. The tipoff came on July 1, 1976, when these departments fell under the initial version of OMB Circular A-110, which Norris (2008) writes was issued "to provide standardized administration of research programs funded by grants and cooperative agreements," with the intent of reducing the burdens of research administrators and the federal sponsors. Implicit in this directive was the idea that more responsibilities were placed upon faculty and research administrators to handle federal awards. This change was prominent compared to the 1960s, when the government took a stronger hand in the administration of research.

The advent of A-110 to explain the maximum requirements that federal granting agencies could put on universities was timely. The mid-1970s witnessed the increased role of research administrators from identifying funding sources and helping with proposals to including negotiations with potential sponsors based on the terms and conditions of awards; and then officially accepting the awards and ensuring compliance with procurement and financial accountability. The question concerned the responsible relationship among the OMB; federal granting agencies for approval authority for purchasing equipment, filing reports, and maintaining auditable financial records; and the universities, which were on the line for compliance. In this mix, university research administrators monitored projects through closeout to watch for abuses in individual rights and responsibilities; protection of living organisms; and fraud, waste, and abuse. Beyond these new tasks, Norris (2008) explains that research administrators had to begin providing "certification or assurance of compliance with the principles in A-110 and to have institutional policies and procedures in place to ensure compliance." In most research institutions, Norris continues, the sponsored programs director was made the official responsible "for coordinating and ensuring" that the requirements were understood and met.

Therefore, the work of the Warner subcommittee occurred during this rapid professionalization of research administration; and it increased the body of knowledge requirements. To serve these developments, the subcommittee identified the purpose of compliance as not to restrict or obstruct science, humanities, and research for the public good. Its work illustrated that the principles ensured progress through shared responsibility of institutions, COGR and OMB without incurring needless burdens on each group.

Politically, Warner's subcommittee constitutes part of the roadmap to freedom in a democratic society. Freedom does not equal license. Too often people interpret, approach, and think of the principles as being obstructive. This was a critical period because with more decision-making handed over to research administrators they had to become more professional in their work with both sponsors and researchers. Research administration practices were formed by these dedicated professionals and federal officials and their cooperation and understanding.

The Subcommittee's Arguments

The subcommittee's philosophy was minted on behalf of research administrators to make "uniform standards make sense to the institutions affected." Its goal was for "one set of requirements in lieu of a multiplicity of sometimes very different rules ..." The standards had to "1) advance the public interest," and 2) be acceptable to the institutions to which the rules applied. Moreover, they must be "reasonable and able to be implemented and complied with without major disruption or cost." With this view, Joseph Warner and his colleagues counseled the government that the time had arrived to remove outdated administrative principles and to "refine, clarify or streamline those which are necessary but cumbersome ... and to simplify and consolidate whenever possible." To ensure uniform standards, Warner's subcommittee wanted to ensure that universities would not have to separately negotiate provisions that were satisfactory to them (Warner, 1975, March 10).

Yale University's comments on the proposed A-110 reflected the goal of standardization and streamlining, and typified the subcommittee's concerns. Mr. Warner was concerned about the definition of "subrecipient" and "substantive work." His comments questioned why separate bank accounts had to be used to reduce administrative burdens and costs. The comments questioned why nonexpendable property records, which were not being maintained for items acquired under grants, had to be maintained because of the cost. Why was there "such a long retention requirement for property records," and what is meant by "three years after its [a piece of property] final disposition," while the cut-off for other records was three years? Yale's comments held that "The rights granted the government are too broad" concerning subrecipients. They should not be vendors or suppliers but only public or private institutions receiving federal funds through a recipient as payment for a cooperative project. Moreover, access to books, documents, papers and records was too broad and should focus on material per specific program. Also, Mr. Warner questioned why technical and financial reports had to be sent together. His argument was that the financials were prepared and certified by university financial affairs staff while the technical reports were written by the principal investigators and read by program officers rather than program financial staff, who were not interested in the technical reports. If needed, he continued, program officers could obtain financial data from counterparts (Warner, 1975, March 10).

The exchange on this point continued until on November 12, 1976, John J. Lordan, Chief, Financial Management Branch, Budget Review Division, OMB, wrote to Warner about the reporting requirements for closeout in A-110. Lordan detected that campuses did not...

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