For the partnership to thrive, there must be a
clear understanding on the part of both parties of the goals of the partnership and the
responsibilities of the partners. Why does the Federal government invest in university
research? What is the role of graduate students in the research enterprise? On what basis
are the costs of research allocated among the parties? Federal laws, circulars, and
regulations govern operational aspects of the government-university relationship in areas
such as allowable costs, administrative procedures, compliance issues, and audit
practices. Yet statements of the rationale, goals, and objectives of the public investment
in university-based research remain implicit, or are dispersed in a variety of legislative
and other documentation. As long as this is so, the government-university partnership
risks being defined primarily in an ad hoc manner, by detailed accounting, administrative,
and financial management requirements, and not by broader national goals. A clearly
articulated statement of the principles of the partnership would help clarify the roles,
responsibilities, and expectations of each of the partners and establish a framework for
addressing future issues as they arise. Ultimately, an agreed upon statement of principles
would also serve to shape future discussions, formulate policies, and help guide decision
making. The process itself of engaging the government and university partners in a
dialogue would increase mutual understanding and provide a good foundation for resolving
complex issues in the future.
The NSTC, in this report, is issuing a proposed statement of the principles of the
government-university partnership. These were developed through interagency review and
discussion that benefitted greatly from the input provided by the university community. It
is imperative that a more extensive dialogue take place among all stakeholders before the
principles are finalized. In particular, it is especially important that universities
become directly involved in these discussions and that the Congress also become engaged.
To this end, the NSTC encourages internal university discussions and inter-university
deliberations, in addition to the dialogue that will be facilitated by the NSTC between
the government and university partners and any congressional deliberations that might
occur.
The goal of all those involved in these discussions should be to foster an environment
that promotes scientific discovery, technological innovation, and the development of the
next generation of scientists and engineers. Government actions should be guided by a
recognition of the national importance of the American university and by a desire to
sustain that special resource for maximum benefit to the nation. It is also important for
universities to demonstrate their understanding of the responsibilities to the American
public that accompany the acceptance of Federal funds for the conduct of research. Both
partners must also be committed to streamlining administrative processes while maintaining
effective stewardship of Federal funds.
| ACTION: Adopt Statement of Principles of the
Government-University Partnership |
| The NSTC proposes a statement of principles of
the government-university partnership to clarify the roles, responsibilities, and
expectations of the parties—funding agencies, universities, individual investigators,
and regulatory bodies—and to provide a framework for the development of new policies,
rules, regulations, and laws affecting the partnership. The NSTC statement of principles
serves as a basis for further dialogue among interested parties, including government and
universities, and should be finalized by the NSTC within twelve months. There will be a
variety of mechanisms provided for facilitating public comment through discussions with stakeholders, who include the Congress, university associations and professional societies, the National
Academy of Sciences, the National Science Board, and the Federal Demonstration
Partnership. |
PROPOSED STATEMENT OF PRINCIPLES
The following are guiding principles that govern interactions between the
Federal government and universities that perform research.
1. GUIDING PRINCIPLES
- Research Is an Investment in the Future.
Government sponsorship of university research—including the capacity to perform
research and the training of the next generation of scientists and engineers—is an
investment in the future of the nation, helping to assure the health, security, and
quality of life of our citizens. Government investments recognize that the expected
benefits of research often accrue beyond the investment horizons of corporations or other
private sponsors. Investments in research are managed as a portfolio, with a focus on
aggregate returns; investments in individual research efforts that make up the portfolio
are based on the prospects for their technical success, though not on a presumption that
those outcomes can be predicted precisely.
- The Linkage Between Research and Education Is Vital.
The integration of research and education is the hallmark and strength of our
nation's universities. Students (undergraduates as well as graduates) who participate
in Federally sponsored research grow intellectually even as they contribute to the
research enterprise. Upon graduation, they are prepared to contribute to the advancement
of national goals and to educate subsequent generations of scientists and engineers. Their
intellectual development and scientific contributions are among the important benefits to
the Nation of Federal support for research conducted at universities. There should be
compelling policy reasons for creating or perpetuating financial or operational distinctions between
research and education. Our scientific and engineering enterprise is further enhanced by
the intellectual stimulation brought to campus by students from varying cultural, ethnic,
and socioeconomic origins.
- Excellence Is Promoted When Investments are Guided by Merit Review.
Excellence in science and engineering is promoted by making awards on the basis of
merit. Merit review assesses the quality of the proposed research or project and is often
used in combination with a competitive process to determine the allocation of funds for
research. Merit review relies on the informed advice of qualified individuals who are
independent of those individuals proposing the research. A well-designed merit review
system rewards quality and productivity in research, and can accommodate endeavors that
are high-risk and have potential for high gain.
- Research Must Be Conducted with Integrity.
The ethical obligations entailed in accepting public funds and in the conduct of
research are of the highest order and recipients must consider the use of these funds as a
trust. Great care must be taken to "do no harm" and to act with integrity. The
credibility of the entire enterprise relies on the integrity of each of its participants.
2. OPERATING PRINCIPLES
The following operating principles are intended to assist agencies,
universities, individual investigators, and auditing and regulatory bodies in implementing
the guiding principles.
- Agency Cost Sharing Policies and Practices Must be Transparent.
As in any investment partnership, each partner contributes to the research endeavor.
While the primary contribution of universities is the intellectual capital of the
researchers' ideas, knowledge, and creativity, it is sometimes appropriate for
universities to share in the costs of the research (and in some cases cost sharing is
required by statute). Cost sharing can be appropriate when there are compelling policy
reasons for it, such as in programs whose principal purpose is to build infrastructure and
enhance an awardee's institution's ability to compete for future Federal awards.
Cost sharing is rarely appropriate when an awardee is acting solely as a supplier of goods
or services to the government since this would entail a university subsidy of goods
purchased by the government. If agency funds are not
sufficient to cover the costs of a research project, the agency and the university should
re-examine the scope of the project, unless there are compelling policy reasons to require
university cost sharing. Agencies should be clear about their cost sharing policies
and announce when and how cost sharing will figure in selection processes, including
explicit information regarding the amount of cost sharing expected.
- Partners Should Respect the Merit Review Process.
Excellence in science is promoted when all parties adhere to merit review as the basis
for distributing Federal funds for research projects and refrain from seeking Federal
funds through non-merit- based means. Federal investments in research are made with the
expectation that the research community will select promising research paths more
productively and wisely by relying on merit review than can a process that bypasses merit
review to directly fund a specific individual or institution. Success in obtaining funds
outside the merit review system can be discouraging to researchers who participate
in the process.
Most significantly, bypassing merit review threatens to undermine research excellence.
Merit review may be used in conjunction with other selection criteria to support agency or
program goals.
- Agencies and Universities Should Manage Research in a Cost-Efficient Manner.
The goal of all those involved in sponsoring, performing, administering, regulating,
and auditing university-based research and associated educational activities of the
research enterprise should be to make maximum resources available for the performance of
research and education. This goal can be accomplished by keeping agencies' and
universities' costs of compliance with Federal requirements to the minimum required
for good stewardship of Federal funds. For example, administrative requirements should
rely on the least burdensome and least costly methods that can effectively provide needed
stewardship. Universities should likewise manage their Federal grants as efficiently as
possible.
- Accountability and Accounting Are Not the Same.
The principal measure of accountability must be research outcomes: have the researchers
carried out a program of research consistent with their commitment to the government?
Financial accountability is also important and should assure research sponsors that
Federal funds have been used properly to achieve the goals of the research in a cost
effective manner. Federal agencies must ensure that financial accountability requirements are limited to
those that are reasonably required for good stewardship and that each measure adds sufficient value in
terms of increased stewardship to justify the burdens and costs it imposes on universities
and agencies.
- The Benefits of Simplicity in Policies and Practices Should Be Weighed Against the
Costs.
The costs and benefits of simplicity in regulatory, administrative, cost accounting,
and auditing practices should be assessed against the costs and benefits of accommodating
diverse Federal programs and the multiplicity of university organizational structures in
determining best policies and practices. "One size fits all," or uniformity for
uniformity's sake, can unintentionally increase requirements and burdens, but a
multiplicity of practices can also be costly. These tradeoffs should be carefully assessed
whenever changes in government-wide or agency-specific policies and practices are
proposed.
- Change Should be Justified by Need and the Process Made Transparent.
The process of change in the government-university partnership should be made as
transparent as possible. Modifications in administrative, regulatory, or auditing
requirements, or in cost sharing expectations, should be kept as infrequent as possible, consistent
with the need to respond to changing circumstances. The impact of change in one part of
the system should be understood relative to the whole. Reasonable time should be allowed
for both agencies and universities to adapt to change. |
