Federal-Wide Research Terms and Conditions
Last October, the National Science Foundation (NSF) published proposed Research Terms and Conditions (RTCs) for Federal awards. The proposed RTCs update the current RTCs by implementing the requirements under 2 CFR 200. In some instances, the proposed RTCs modify the requirements under 2 CFR 200 to address the unique nature of research awards.
The Federal Register notice stated that the “use of RTCs is envisioned as a streamlined approach that supports the implementation of the Uniform Guidance by providing clarification, supplementary guidance, and, where appropriate, selected options, while meeting the spirting and intent of a uniform implementation.”
The NSF developed a crosswalk that identifies the differences between 2 CFR 200 and the proposed RTCs. All provisions in 2 CFR 200 would apply to research awards unless identified on the crosswalk.
Upon final completion and approval of the RTCs, the Federal research awarding agencies will release three appendices to the RTCs:
- Appendix A, Prior Approval Matrix
- Appendix B, Subaward Requirements Matrix
- Appendix C, National Policy Requirements Matrix
The NSF is the lead agency on developing the RTCs. Others Federal agencies participating in the development process include:
- Department of Commerce – National Institute of Standards and Technology (NIST)
- Department of Commerce – National Oceanic and Atmospheric Administration (NOAA)
- Department of Energy
- Department of Health and Human Services – National Institutes of Health (NIH)
- Department of Homeland Security
- Department of Transportation – Federal Aviation Administration
- Environmental Protection Agency
- National Aeronautics and Space Administration (NASA)
- National Science Foundation
- U.S. Department of Agriculture – National Institute of Food and Agriculture
The NSF has not announced when the RTCs will be finalized. In the Federal Register Notice, the NSF wrote: “After obtaining and considering public comment, the [Interagency Working Group] will prepare the format for final clearance.” The public comment period closed on December 14, 2015 and the NSF received two comments.
The Government Accountability Office (GAO) released a report in June 2016 entitled Federal Research Grants: Opportunities Remain for Agencies to Streamline Administrative Requirements. The GAO report provides extensive background to the development of the RTCs and made recommendations to reduce recipient administrative burden.