MLA/AAHSL Joint Legislation Responds to OMB Proposal

Submitted by: Ryan Harris

Many of you know that the Office of Management and Budget released its proposal to revise the Guidance for Federal Financial Assistance. There were significant changes with this proposal, and because of this, the MLA/AAHSL Joint Legislation Committee thought it was important to develop a response to the proposal. The committee brought together a group of volunteers to craft a response.  Two main areas were the focus of the response:

• The cost of subscriptions to periodicals would become unallowable with grant funds. This is important because for many health sciences libraries, the library receives a portion of grant indirect costs (F&A) and uses those funds to purchase library resources, including journal subscriptions.
• Article Processing Charges (APCs) will be unallowable under Federal awards. This is important because many of the researchers at our institutions use their grant funds to cover APCs. Researchers are unlikely to have other funds to pay APCs, which will limit where they can publish their research, especially NIH-funded research.

Feedback from the larger Joint Legislation Committee was incorporated into the final response draft.

Many thanks to the volunteers for the work on the response under a tight deadline: Terrie Wheeler, Deb Werner, Katie Funk, Jonah McAllister-Erickson, Carrie Grinstead, and Lena Bohman.