Admin Burden in Canada/Issues

From CASRAI

The following matrix of issues have been collected by the ABC Steering Committee.

Personnel Recruitment

Current State (issues) Responsible Gov Units Desired State (solutions) Current Pan-stakeholder Initiatives
Advertising time frame unwarranted. Time limits invalidate appointments. Immigration Canada Alignment of time limits with academic business needs. n/a
Labour market opinions unwieldy. Costs and complexity extreme; lack of consistency in opinions. Immigration Canada Consistency and predictability of labour market opinions. n/a
Work permits not timely. Time required to obtain work permits for visiting scholars etc. not realistic. Immigration Canada Alignment of work permit requirements with academic business needs. n/a
Sole source requirements counterproductive.  Where very highly specialized research expertise is required, sole source requirements for contracts are both unwieldy and often likely to preclude effective matching of supply with demand. PWGSC; Provinces n/a
Undue documentation requirements. Research Specialists to be appointed as consultants can require extensive justification and separate RFP incurring undue work and delays. Focus on deliverables, not process (that should be under the remit of universities and colleges in any event) n/a

Program Design

Current State (issues) Responsible Gov Units Desired State (solutions) Current Pan-stakeholder Initiatives
Proliferation of program modalities without sufficient rationale. Programs and priorities often developed by multiple agencies around converging goals but with differing mechanisms, deadlines and approaches among agencies. Federal agencies - TC3+, Genome Canada, CANARIE Coordinated actions among funding agencies with deadlines aligned and synergy of approach. n/a
Lack of interoperability of peer review across programs. Need for improved interoperability of peer review to reduce burden on peer reviewers - eg: NSERC/Mitacs/ NCEs/CRC/CFI Tri-councils Standardized information formats for flowing/reusing funding application data between review panels. CASRAI standard information agreements for portable funding applications.
Redundancies in Joint intiatives (e.g. CHRP program). There are often redundancies in application materials to meet multiple agency standards; this is a waste of time and acts as barrier to industry/knowledge user partners Tri-councils Standardized information formats for flowing/reusing funding application data between review panels CASRAI standard information agreements for portable funding applications.
Bypassing institutions in agreements. Some agencies are proceeding with funding agreements signed by researchers, not authorized signatories of colleges/universities. Provincial funding agencies Engage offices of research early; have authorized signatories sign applications submitted,  provide Ts and Cs at solicitation stage; send draft contracts for office of research review n/a
CV information not harmonized. Data standards for CV information not adopted. Insufficient harmonization of information requirements.  Differences among data elements required by different agencies more apparent than real; need to revisit. Tri-councils; Provincial funding agencies Write once/reuse anywhere; researcher should be able to flow/reuse CV data across any funder. More harmonization of required information fields CASRAI standard information agreements on CVs now existing - value in pursuit of enhanced implementation;  CARA -  sharing best practices (discussion phase)
Funding application requirements not harmonized. Data standards for funding application information not negotiated or implemented. Tri-councils; Provincial funding agencies Write once/reuse anywhere; researcher should be able to flow/reuse project data across any funder CASRAI standard information agreements for portable funding applications.
Contract rigidities. Contract terms are stringent and firm, without potential negotiation space for universities. All federal departments used to use standardized clauses in contracting.   The absence of this is a major barrier to efficiency. Tri-councils; PWGSC; other federal (Crown) agencies Some value in returning to standardized contract terms (SAAC in disuse), clauses and conditions from PWGSC specifically for universities. An agreed template with universities might help but willingness to negotiate and take into account the specificity of agreements might also help. Departments and  Agencies should have university/college specific standard terms and conditions for contracts and not try and make their contracts fit a consulting agreement with industry n/a
Indirect costs determination not standardized. Indirect costs negotiation is always a hassle with provincial and federal agencies, despite the IC programs for tri-council and provincial funding agencies. Tri-councils; PWGSC; other federal (Crown) agencies Develop a common protocol for determination of indirect costs n/a
Undue financial reporting requirements for entities within a PSE institution. Some grants require an audited balance sheet and cashflow statements for grants to research institutes within universities which are not separate legal entities Industry Canada Granting agencies should have university/college specific standard terms and conditions for contracts  and not try and make it fit a standard third party contract agreement n/a
Individual eligibility rules inconsistent. Different eligibility criteria for holding awards and different timing and processes for confirming on-going eligibility Tri-councils Consistent guidelines and single annual process of confirmation of on-going eligibility n/a
Eligibility and monitoring of funding sources. Monitoring of co-funding is becoming a post-award nightmare, for finance and for keeping track of what has been committed as co-funding. Double and triple use of resources is appearing without clear rules on how to manage this and difficulty to evaluate the reality of what is committed (if it is new resources or not)
Terminology Consistency. Consistency and clarity of terminology and eligibility across disciplines/TC3 domains
Matching Funds. Much wasted time could be saved if the various programs that require matching funds could have consistency in approach, definitions and understandings.
PDF and RA Policies. Significant differences among the funding agencies that is counter-productive. Clarify and make consistent among agencies and institution definitions of PDF and RA and policies relating to them – e.g. how long a person may be deemed a PDF.  When you are dealing with collaborative research initiatives dealing with different institutions and across jurisdictions/provinces this also can be a problem (i.e. not just with the agencies). This is an issue that also touches collective bargaining.

Financial Compliance

Current State (issues) Responsible Gov Units Desired State (solutions) Current Pan-stakeholder Initiatives
Layering of financial requirements on Pis and institutions without understanding of cost-benefit balance. Over time there has been increased financial authority required of Pis that has in turn required corresponding institutional workload and requirements. Tri-councils Risk-based approach that incorporates materiality while maintaining proper accountability and the exercise of due diligence CAUBO working group looking at cost/benefit analysis re: approvals required for small expenditures regardless of materiality and risk levels (small dollar value items and/or internal charges such as photocopier charges)
Overly onerous accountability for funds management and compliance when transferring across multi-sites especially outside of university and college sector Tri-councils n/a
Undue documentation expectations. The level of justification required for standard, small dollar purchases is not commensurate with the risk Tri-councils Risk based (including due consideration to materiality) approach to documentation and justification requirements n/a
Undue documentation expectations. The requirement for written justification has increased significantly without commensurate accountability (e.g. for computer purchases, cell phones, printing & stationery Tri-councils Items should be eligible or not eligible. Being required to include a written justification imposes a significant burden on Pis without adding value n/a
Inconsistent or vague guidance on eligibility requirements. Requirements different for NSERC, SSHRC and CIHR at times. Tri-councils Standardized approach to providing eligibility rulings, perhaps from a central group? n/a
Intra-Council inconsistency of approach. Inconsistent approach among tri-council staff causes additional work at the institutional level, e.g. reconciling rulings provided by financial staff that are inconsistent with requirements asked by monitoring teams. Tri-councils Consistent approach from all tri-council staff and more clarity in the TAFAG so that expectations are clearly articulated and apply to all institutions n/a
Clarity of Tri-council monitoring teams expectations and requirements. These may go beyond that of the TAFAG and are not communicated widely so those institutions not being monitored often feel they don't need to comply Tri-councils Any clarification or interpretation being insisted on by monitoring team during a review should be documented and widely communicated so that all institutions are aware of it and have to comply with it. n/a
Rationale for rules unclear. Certain rules do not appear to make sense or are very difficult to justify to researchers (e.g. detailed trip purpose, two year limit on PDFs on grants etc., very limited printing & stationery expenses on grants etc.) Tri-councils Working group could be set up between tri-council and institution reps to review some of these contentious areas n/a
Undue time spent in allocating legitimate research costs to a cost centre. The eligibility rules for RSF are quite limited, while restrictions on what may be charged as a direct cost of research have tightened. Significant time is spent in finding appropriate cost centers for such charges. Research Support Fund Extend eligibility to allow some of the low dollar items no longer eligible under direct costs to be eligible under RSF (e.g. printing & stationery costs) n/a
Undue documentation expectations: time sheets requirement at odds with normal business practice in universities PWGSC Institutions do not typically keep time sheets so this requirement should be removed n/a
Onerous documentation requirements. Original receipts requested where not commensurate with risk PWGSC Copies of receipts can be provided but this should be on a sample basis only or preferably the project should be the subject n/a
Payment requirements do not reflect how universities and colleges operate. Contract requirements, e.g. having to report actual payroll costs at an estimated daily rate, do not reflect how universities operate and add significant administrative burden without apparent returns. PWGSC Reporting requirements should reflect how institutions operate n/a
Frequency of reporting can be excessive. Certain programs require reporting within 5 business days of month end and many want monthly reporting, incurring significant workload NRC, IRAP Reporting frequency should ideally be quarterly, monthly only if absolutely necessary. n/a
Supporting documentation required is excessive, e.g. 100% of all expenses need back up documentation NRC, IRAP Programs should be subject to audit rather then require back up for expenses on a regular basis. n/a
Inconsistent policies on benefits among departments/agencies. Benefits are not allowed or in some cases are capped at a certain percentage. NRC, IRAP, FedDev Federal gov agencies should be consistent and all allow benefits at whatever the institutional rate is for that category of employee n/a
Inconsistent policies on record retention. Record retention outside normal 7 year time frame creating undue admin workload. FedDev All federal agencies should have the same document retention period as per CRA guidelines, i.e. 7 years from date of transaction n/a
Differing policies on HST as an allowable expense. Lack of consistency on whether HST is an allowable expense against a grant/contract causing time wasting NRC - EcoEnergy program GST/PST/HST should all be allowed on federal government grants n/a
Lack of attention to materiality. Financial officers go through the report in detail recalculating the recoverable HST and making tiny adjustments (e.g. under $5) PWGSC - CSA
Need to balance burden of monitoring visits with ROI - time, efficacy, detail, materiality Risk-based approach that reflects materiality CAUBO has a Working Group active on this issue - see above
Need to balance admin burden with ROI - CCAC (time, efficacy, detail) and Line dept audits Risk-based approach that reflects materiality n/a

Non-Financial Compliance

Current State (issues) Responsible Gov Units Desired State (solutions) Current Pan-stakeholder Initiatives
Ethics admin burden - undue variation in requirements re data use; lack of interoperability of multi-site reviews causing much duplication of workload Advance data standards for the ethics-related information that must pass between different sites. n/a
Lack of common compliance standards - Animal/human/radiation/bio/EHS Advance data standards for the other compliance-related information that must pass between different sites. n/a

Post-Award Management

Current State (issues) Responsible Gov Units Desired State (solutions) Current Pan-stakeholder Initiatives
No agreed or common standards for publishing funding results.  There is an explosion of different extranet sites that require research offices to to master and use different protocols in order to access information from each agency Tri-councils; Provincial funding agencies Funders publish results in a standard, software-readable format CASRAI standard information agreement on Funding Results established; implementation pilot to run 2015-2016 (NSERC, SSHRC, UofT, uSask, Research Manitoba)
Bureaucratic rigidities. These include delays in issuing awards, and restrictions to carry forward funds (both pose challenges for graduate recruitment and meeting project objectives) Provinces Provide flexibility for carry forward if the award notice is delayed n/a
Waiver of moral rights, sponsor ownership of IP and deliverables PWGSC; Provinces, Crown agencies Program and contracting officers need to be more clear and transparent with researchers in terms of what this means to their, and their students’, academic publication rights
n/a
Delay in issuing awards. This may be characterized as ministerial delays but there may also be other possible sources. The end result can be significant admin burden in managing student, PDF and RA appointments vital to achieving project objectives. Tri-councils; Ministers Remove delays. n/a
Payments. Institutions must register with each individual agency for direct deposits One central registration for direct deposits for all federal agencies

Reporting

Current State (issues) Responsible Gov Units Desired State (solutions) Current Pan-stakeholder Initiatives
Institutional reporting requirements to multiple agencies inconsistent and unduly onerous. Reporting often requires duplication across agencies Tri-councils; Provincial funding agencies All federal agencies should use the same reporting requirements and reporting template; related to above lack of information standards CASRAI standard information agreements for research outputs, outcomes and impacts
Institutional interoperability of admin data. Sharing among institutions. n/a CASRAI standards could provide foundation; U-15 have advanced documentation and interoperability
Reporting required of individual PIs unduly onerous. Multiple different reports required in different formats and standards, for different periods post award. Tri-councils TC3 to harmonize reporting requirements inasmuch as is possible, working in consultation with institutions
CASRAI mechanisms establish for pan-stakeholder consultations and common framework
Additional reporting requirements introduced as barrier to access to Indirect Cost funds.  Additional requirements have been imposed including identification of performance indicators for indirect costs before being able to apply for 2015-16 . Reporting requirements at odds with funding of the real indirect costs. Tri-councils - Research Support Fund Given the very low rate of overhead recovery from this fund (i.e. 20% when actual overhead rates are at least 40%) reporting should be kept to a minimum. CASRAI Interest Group on Research Administration KPI standards
Lack of coherence in societal impact reporting - unclear metrics, duplication across agencies Common, extensible impact metrics and underlying source data Casrai standards for research impact indicators

Scholarly Communications

Current State (issues) Responsible Gov Units Desired State (solutions) Current Pan-stakeholder Initiatives
Lack of clarity on requirements and funding eligibility for Open Access (OA) and Open Data (OD) compliance Tri-councils; Provincial funding agencies Adopt data standards for OA reporting. DOI and ORCID should be promoted and DOI could be included in references from researchers within CVs Casrai standards are being developed in the UK for portable OA reporting across multiple funders; also Casrai standards for OA repository interoperability so funders could better aggregate compliance data across multiple sites
Policy impacts. Need to anticipate the impact of Open Access and Open Data policies and expectations