FDP Expanded Clearinghouse – Phase 2 Proposal Page 4
1.5.3 Administrative Support and Oversight
The ECWG will operate as the support team for the Online Clearinghouse preforming the following tasks:
• Develop and maintain all necessary user documentation, FAQs, surveys and reports
• Provide EC-SDWG necessary list of values or detailed functional requirement for areas such as data elements to
base alerts on, key fields for validation, etc
• Review each profile when submitted or modified and review all profiles regularly to ensure data integrity remains high
• Monitor use of the clearinghouse including dates of API downloads by users, frequency of updates by users and
other functionality to monitor the needs of the clearinghouse
• Maintain awareness of needs related to changes in data elements, additions, deletions or modifications
• Coordinate communication among the users and provide users regular updates and status reports on the Pilot
• Receive and track ongoing feedback from the users
• Maintain all user required resource documents on clearinghouse webpage
• Maintain clearinghouse webpage overall
• Coordinate review of overall clearinghouse at least annually on an ongoing basis
2.0 CURRENT SYSTEM SUMMARY
There is currently no single, on-line electronic database containing all information needed for pass-through entities to perform
risk assessments and to do ongoing monitoring of static or annualized data related to subrecipient monitoring. Select data are
instead housed in certain federal government systems, such as the System for Award Management (SAM) or the Federal
Audit Clearinghouse (FAC) with the remainder retained by the individual entities themselves. Certain data expected under the
Uniform Guidance to be used for this purpose are as yet unavailable nationally to pass-through entities, including copies of A-
133/Single Audits or federal management decisions. This lack of data and dispersion of data led to research institutions
creating data collection documents used with each other at time of subaward issuance or updating. The plethora of forms
coupled with most institutions collecting data on a per-subaward basis rather than on a per-entity basis has led to significant
administrative burden without commensurate benefit from a risk management perspective.
The FDP Expanded Clearinghouse Phase 1 Pilot created a process whereby each pilot entity could provide a standard set of
data and answers to questions in the form of an Entity Profile. These Entity Profiles are currently maintained in excel and
converted to pdf for to a centralized web site repository. Data relative to administrative burden relief is being captured and will
be reported quarterly beginning Fall 2016; early data suggest the relief will be meaningful. The current process, however,
relies on limited data validation opportunities on the profile form itself, as well as significant manual review,
approval/certification and loading of documents by multiple individuals involved in the process (institutional representatives,
FDP Expanded Clearinghouse volunteers, and FDP staff.) The profiles themselves generally require updating at least twice
per year, resulting in significant ongoing burden. In addition, download of data for use in local systems is not available.
These results, along with the remarkable success of the original FDP Financial Conflict of Interest Clearinghouse that was
eventually opened to non-FDP members and now includes more than 1000 entities, signified a need to change to a more
automated and electronically robust process for the longer term. This proposal reflects the FDP’s efforts to build that
electronically robust system.
3.0 FUNCTIONAL REQUIREMENTS AND USER IMPACTS
3.1 Summary of Functions
The FDP Expanded Clearinghouse requires a technology based solution for a community-wide data collection and
management system whose primary functions include:
• Data Accessibility
• Entity Profile Administration
• User Accounts
• Data Integrity
• FDP Administration Panel
• System Security
• Links to related systems/external compliance databases