93 



In response to this evasion of the certification requirement, 

 officials in NSF's Office of Inspector General told us that they 

 were concerned about the need for more complete certification 

 procedures. Such procedures would require applicants to certify, 

 under criminal penalties for perjury, exactly what, if any, 

 applications for similar research were pending in other agencies. 

 These officials also recommended that the existing NSF 

 certification form should be revised and strengthened. The agency 

 agreed and implemented this recommendation. SBA's Assistant 

 Administrator told us that the forms in use in other agencies could 

 also be reviewed and, if necessary, revised and strengthened to 

 address potential problems with certification. 



Second, the lack of definitions and guidelines regarding key 

 terms such as "similar" research has resulted in disagreement about 

 what constitutes duplicate research. SBA's policy directive and 

 individual agency solicitations do not define key terms and thus 

 provide no guidance in avoiding the risk of duplicate funding. 

 According to an SEA official, certain key terms--such as 

 "duplicate," "similar," "equivalent," "overlapping," "substantially 

 similar," and "proposals of similar content"--occur in the 

 solicitations. However, little effort has been made to bring them 

 into the context of scientific research and give them a more 

 specific meaning. 



In fact, the vagueness of key terms can lead to differences of 

 opinion by federal and company officials. In one case, NASA 

 officials became concerned that a company, which received Phase I 

 and II awards from NASA and the Army for potentially similar 

 research, did not inform NASA of the Army awards. The company 

 contended that it did not inform NASA of the Army awards because, 

 in its view, the research was not duplicative. NASA disagreed and 

 rescinded the company's Phase II award. 



