OIG response re. COGR

Dear Ms. Mar:
In response to NSF’s Notice in the Federal Register (Vol. 77, No. 179, Sep 14,
2012), we received three comments, including one from the Council on
Governmental Relations (COGR). Our application package to OMB included our
response to COGR (Statement A, p. 5—Commenter 2, which we also provided
directly to COGR), which was published in the Federal Register (Vol. 78, No. 105,
May 31, 2013). COGR then submitted a second comment in response this Notice,
which was addressed to you. This second comment is largely duplicative of the first
one.
COGR’s “principal and over-riding objection” to our data collection is that it is
“not necessary to affirm compliance with the policy requirement”, and thus is
excessively burdensome on the community. COGR suggests we need only the
grantee’s plan and verification of student attendance to assess compliance. If we
followed COGR’s suggestion to limit our effort and determine only whether grantees
were complying with NSF’s requirement to have a program, there would be little
value added. COGR has apparently missed the purpose of our project as stated in
the Notice in the Federal Register. Assessing institutional compliance is only part
of what we hope to accomplish. As we stated:
This information collection is necessary for review of
institutional compliance with the responsible conduct
of research requirements. NSF OIG will primarily use
the data collected to inform the Foundation and
Congress
whether
current
responsible
conduct
of
research programs comply with NSF’s requirement and to
make recommendations to strengthen these programs if
necessary. The results of the information collection
also will assist NSF OIG in developing a responsible
conduct of research oversight plan.
Thus, we stated we are interested not only in whether grantees minimally comply
with the requirement, but how they comply. As noted, this additional information
will be used to make recommendations to NSF about strengthening the RCR
program, if necessary. As one example, both NSF and NIH have RCR programs
with which grantees must comply. NIH’s program is much more prescriptive than
NSF’s. We would like to know how grantees meet the disparate requirements of
both agencies and whether a more unified approach would better serve NSF and the
grantees. In our response, we confirmed we are requesting the documents COGR
suggests: the grantee’s RCR plan and verification of student and post-doctoral
training. The additional documentation we propose collecting is a description of
course materials and information regarding resources available to the program.

Our sample engagement letter was provided in our package (Appendix A1engagement).
COGR complains that Investigators may have to take time to respond to us
rather than work on their research. We are not requesting to speak with any
Investigators, although Commenter 3 suggested our list of interviewees was
incomplete because we did not include faculty. As we noted in both our Federal
Register Notices, we are requesting to talk to one representative of a grantee’s
leadership, the RCR course administrator, and students and post-docs who have
received the RCR training. One could argue that post-docs and students should
remain in the lab conducting research, but since the RCR training is supposed to
benefit students, we believe it is paramount to include students and post-docs who
want to talk to us about their RCR training experience. Contrary to COGR’s view,
another commenter (Commenter 1 to the second Federal Register Notice) suggested
we talk with more students, not exclude them. We have made a judicious effort to
minimize the burden on the grantees, as described in Statement A, part A.12 (we
are only asking for 1 hour of students’ time from fewer than 100 of NSF’s
approximately 3100 grantees). Commenter 1 also observed the most effective way
to reduce the burden on respondents would be to give clear and timely guidance
about what constitutes adequate RCR training. As we noted in our response:
NSF has not specified what constitutes ‘adequate’ RCR
training.
We are assessing how grantees have
implemented NSF’s requirement, how many of them would
welcome further specificity in NSF’s requirement, and
how many would not—and why or why not.
As we note,
one
likely
outcome
of
our
effort
would
be
recommendations back to NSF for improving its RCR
program, and, depending on the response data, this
could be one of those recommendations.
This is our responsibility under the Inspector General Act “to promote economy,
efficiency, and effectiveness in the administration of” NSF programs.