The review identified a number of actions that would help make the partnership more effective and efficient.
Although a number of Federal agencies have policies regarding research misconduct, not all do, and variations in policy and practice send mixed signals to universities regarding Federal interests in this area. The interests of the Federal government will be advanced if greater uniformity can be brought to Federal policies in this area and universities will find more consistency in their interactions with government agencies.
As a major funder, producer, and user of research, the Federal government has a vital interest in the integrity of the research record. Advances in science and engineering depend on the reliability of the record as do the benefits associated with them in areas such as health and national security. Sustained public trust in the scientific and engineering enterprise also requires confidence in the record and in the processes involved in its ongoing development. There will be occasions when it will be alleged that an individual researcher has failed to act in accordance with values of the scientific and engineering enterprise, values essential to public confidence in the enterprise and the integrity of the research record. In such cases, the Federal government must have clearly stated policies defining the circumstances under which it will consider that research misconduct has occurred in the course of Federally funded research, and guidelines for addressing such allegations.
Although most parties would agree with the principle that excellence is promoted by rewarding merit, exceptions to merit review do occur in awarding research funds. It is in the interest of both the universities and the Federal government to ensure that merit review is well understood by the stakeholders, and to maintain the integrity of the process.
Both universities and the Federal government need to be able to explain how funding decisions are made. When universities or other organizations seek research funds though non-merit-based means, the integrity of the enterprise suffers, which could ultimately undermine support for Federally-funded research. Both partners should seek ways to explain and defend the merit-review process, and to ensure that awards made outside of the merit review process decrease over time.
Cost sharing, as defined in OMB Circular A-110, "Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and other Non-Profit Organizations," is that portion of project or program costs not borne by the Federal government. With the exception of cost sharing that is required by law, agencies vary in their approaches to cost sharing and most do not have explicitly articulated, agency-wide policies. Individual program managers therefore often make decisions on a program-by-program basis. Actions taken by program managers may make sense from an individual program perspectivecost sharing can be a means of maximizing the number of awards within limited budgetsbut the cost/benefit analysis may look different from an agency or even a national perspective. Universities have four principal sources from which to draw funds to support their activities. These are tuition, gifts, Federal funds, and state funds in the case of state universities. Ad hoc cost sharing practices can have a detrimental impact on the university research and education system as a whole (for example, by drawing funds for research from sources that would otherwise support undergraduate education). And while it can be in the governments interest to accept universities offers to share in the costs of research in cases where it is not required, certain accounting rules tend to discourage universities from volunteering to do so.
A number of issues identified by this review merit action:
4. Grants Administration
Issue: Differences in policy and practice across Federal agencies oblige institutions of higher education to maintain separate internal operating procedures for each agency with which they conduct business. Programmatic variations among agencies may justify some of these differences. However, opportunities to streamline excessive requirements could save time and resources for universities as well as for Federal agencies.
More uniform policies and procedures for the administration of Federal research project grants can reduce paperwork and free faculty to spend more time on research. The Federal Demonstration Partnership (FDP) has developed standardized grant terms and conditions to apply to all FDP institutions that receive support from FDP agency members. These streamlined standards have helped reduce the burden placed upon researchers and university administrators by narrowing the differences in grants management practices among agencies, but without compromising accountability. However, not all agencies participate in the FDP, and only 65 universities are members. The benefits of streamlined standards and uniform terms and conditions could be extended to those other agencies and universities by making them applicable across all agencies. Agency efforts to reduce agency-specific requirements should also continue.
Universities have expressed serious concerns about the cumulative impact of Federally mandated requirements in business practices. For example, the implementation of Cost Accounting Standards (CAS) by the Cost Accounting Standards Board imposed administrative burden on universities, while provisions in OMB Circular A-21 place limits on the recovery of both administrative costs and other costs associated with operating the research enterprise.
The implementation of CAS is an example of what can happen when Federally mandated business practices are implemented without consideration of their cumulative impact. In 1996, OMB incorporated the requirement to comply with four cost accounting standards in OMB Circular A-21, and, for institutions with Federally sponsored agreements totaling $25 million or more, the requirement to file a Disclosure Statement. The latter describes the cost accounting practices of the institution, and provides the cognizant Federal agency the ability to determine whether the institution is in compliance with the CAS.
Certifications and assurances are used by agencies to obtain institutional and individual agreement to comply with the relevant national policy requirements. The two mechanisms are implemented and enforced differently, creating administrative complexity, yet a single mechanism might suffice.
Universities are subject to many national policy requirements by virtue of receiving Federal grants and contracts. The requirements originate in approximately thirty statutes, Executive Orders, treaties and conventions, and are often further delineated in implementing regulations. Examples of current requirements are those concerning nondiscrimination on the basis of race, color, national origin, religion, sex, age, or handicap; the treatment of live organisms, including humans and animals; and environmental quality.
Over the past few decades the Federal government has established national environmental standards applicable to all sectors of the U.S. economy. Some research laboratories and industrial firms have developed tailored, laboratory-based environmental and safety management systems that sometimes exceed the relevant state and Federal levels of protection required by law, even resulting in lower cost, improved research productivity, improved employee safety and health, and better protection for the environment. Implicit in this approach is the recognition that ensuring safety and environmental protection is not just a matter of compliance with regulations, but is consistent with "doing good science."
Recent environmental, health and safety incidents at U.S. research laboratories remind the scientific community that excellent science must also be safe science. Safety and environmental protection measures must be integral to research activities; every scientist and engineer is responsible for designing such measures into their research and for ensuring that students working with them are educated and protected about the risks involved in working in a laboratory. Scientists, engineers, and research laboratories funded by the government should strive to be exemplary in this regard.
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