Response to NSTC Report on "Renewing the Federal
Government-University Research Partnership for the 21st Century"
In September 1996, a Presidential Review Directive (PRD)
was issued in an effort to address the increasing tensions
between research universities and the federal government.
OSTP led the National Science and Technology Council (NSTC)
review along with six major federal research agencies or departments:
NSF, NIH, NASA, and the Departments of Defense, Energy, and
Agriculture. OMB also contributed to the review process. OSTP
consulted widely with the university community in providing
counsel to the NSTC. As part of that consultation effort,
AAMC was asked its views on the status of the government-university
partnership. In an August 15, 1997 response, the AAMC called
for the development of a principles document to guide the
federal-university research relationship. On May 28,
1999, President Clinton released the report from the NSTC
on the PRD and on ways to strengthen the federal government-university
research partnership. The following letter is AAMC's response
to that report.
September 13, 1999
The Honorable Neal Lane, Ph.D.
Assistant to the President for Science and Technology
Office of Science and Technology Policy
Executive Office of the President
Room 432 Old Executive Office Building
Pennsylvania Avenue and 17th Street N.W.
Washington, DC 20502
Dear Dr. Lane:
The Association of American Medical Colleges (AAMC) noted
with great interest the release earlier this year of the National
Science and Technology Council’s report on “Renewing the Federal
Government-University Research Partnership for the 21st Century.”
We have distributed the report widely to medical school and
teaching hospital administrators and faculty. In addition,
Dr. Sybil Francis of your office visited the Association a
few months ago and briefed our staff and invited guests on
the report and the interagency discussions that led to its
conclusions. Based on this extensive discussion and
review, the Association provides the following general comments
on the report.
In the Association’s August 15, 1997, letter to your office
commenting on the status of the government-university partnership,
we urged that three priority issues be addressed to strengthen
and solidify the government-university partnership and re-introduce
a sense of stability in the business climate for research:
- The fundamental assumptions underlying federal sponsorship
of university research need to be reaffirmed.
- The terms of the partnership need to be stabilized.
- The federal government needs to strengthen mechanisms
of consultation and dialogue that allow it to broaden its
perspective, in order to evaluate better the aggregate,
cumulative, and unintended consequences of incremental (and
seemingly continuous) changes in federal policies.
We believe that the NSTC’s report makes significant and constructive
progress in addressing each of these issues. We look
forward to working with the staff of the OSTP, the agencies
and offices represented on the NSTC, and with our colleagues
in the academic community as the report’s recommendations
are brought into practice through changes in regulations,
statutes, and/or operating procedures. While we agree
with almost everything stated in the report, there are a number
of areas where we would like to add emphasis and urge explicit
clarifications.
Proposed Statement of Principles
We agree with the NSTC that the dispersed nature of the rationale,
goals, and objectives of the public investment in university-based
research has led to the partnership’s “being defined in an
ad hoc manner, by detailed accounting, administrative,
and financial management requirements, and not by broader
national goals.” In our view, that is exactly what has
happened over the past two decades. As a result, the
fundamental underlying principles governing the relationship
have become unclear, and trust in the durability and dependability
of the partnership has eroded. We share the NSTC’s view
that extensive dialogue on the proposed principles — involving
government agencies, the academic community, and Congress
— is essential.
Guiding Principles: We agree with the draft set of
guiding principles. The principle stating the vital
linkage between research and education is particularly important.
This linkage is an excellent example of how administrative
and accounting rules can blur and undermine principles when
they are not clearly articulated and mutually agreed upon.
This issue is particularly problematic in the medical school
and teaching hospital environment. As we noted in our
earlier comments on the government-university partnership,
“Enormous amounts of energy are wasted trying to categorize
faculty and students into research, teaching, or patient care
slots in defiance of their ineluctable interdependence, seemingly
because of ignorance of, or apathy to, the multiple missions
of academic medicine.”
Operating Principles: We agree with the draft set
of operating principles. It should be stressed that
systems to manage research should consider both cost-effectiveness
and the university environment, e.g., the varied roles of
students and faculty, the methodological and philosophical
difficulties of faculty effort reporting, precisely characterizing
mixed function space, etc. Concerning the principle
related to the need to justify changes in the partnership,
it should be emphasized that research and graduate student
education are long-term commitments, and the need for stability
in the system cannot be overemphasized. The policies
governing the government-university partnership must be stable,
and the rules that follow, durable, to allow the risks to
universities of such enormously expensive, long-term undertakings
to be measured with confidence and certainty.
Integration of Research and Education
The NSTC report’s emphasis on reaffirming the importance
of the integration of research and education is particularly
welcome. An important consideration in the NSTC’s continued
discussion of this issue is the need for consistent policies
across federal agencies and departments, including, for example,
interpretations from the offices of inspectors general and
the Internal Revenue Service.
Actions to Strengthen the Partnership
The NSTC report identifies many of the critical issues challenging
the federal-university research partnership, the resolution
of which would make the enterprise more effective, efficient,
and harmonious. Federal agency staff, as well as those
in the academic community, must recommit themselves toward
finding innovative and flexible solutions to these vexing
issues.
Research Integrity: We have strongly supported efforts
by the NSTC to develop a government-wide definition and institute
uniform government policies and practices for research misconduct.
Any government-wide policy should reaffirm the primary role
of universities in promoting research integrity and in investigating
allegations of misconduct involving their faculty.
Merit Review: We applaud the report’s reaffirmation
of the principle of merit review in awarding research funds.
The failure of the Congress to fund adequately a peer reviewed
facilities construction and renovation program has led many
institutions to seek directly appropriated facility earmarks.
We urge the NSTC agencies to work with Congress to provide
funds to meet such infrastructure needs, within a strict merit
reviewed framework, in an effort to alleviate some of the
pressure to seek facility earmarks through the appropriations
process.
Cost Sharing: One of the most important areas of the
NSTC’s report is the section entitled “Cost Sharing Policies
and Practices.” This is a very difficult area that benefits
from open discussion and deliberation. This is much
more than an accounting issue. Cost sharing practices
often reflect the philosophical approach that a particular
agency brings to the grant-making arena. While we acknowledge
that cost sharing is appropriate when policies are clearly
articulated and rationalized, as with infrastructure funding,
in too many cases cost sharing has been allowed to distort
the competitive, merit, peer review system.
The NSTC report’s discussion of the cost sharing issue is
an excellent beginning to a more specific and detailed discussion
of this issue. We are pleased that such a discussion
is currently underway, being led by the Association of American
Universities, the Council on Government Relations, and the
Federal Demonstration Partnership, of which we are an affiliate
member. We are anxious to contribute to these efforts
in any way that may be productive. We also believe that
the recently promulgated National Science Foundation cost
sharing policy is very useful, but remain skeptical that such
a policy can be uniformly enforced at the programmatic level,
when in times of scarce resources difficult choices must be
made between competing institutions and investigators.
We are pleased that the report calls for a review of the
limitations on institutional reimbursement of otherwise allowable
research costs. Capping the recovery of administrative
expenses while at the same time steadily increasing the administrative
burden of meeting expanding regulatory and reporting requirements
simply transfers mounting costs to the awardee institutions.
The ability of institutions to absorb these costs has long
since passed. Other important reimbursement limitations that
should be scrapped include capping salary levels reimbursable
by NIH grants below the actual salaries paid to investigators,
limiting pre- and post-doctoral stipends on fellowships and
training grants below the levels many institutions must pay
to remain competitive, and capping recovery from federal grants
of graduate student tuition costs below that charged by many
institutions. The last is especially odious, as it selectively
discriminates against private universities, which receive
little or no state support, and for whom tuition income is
a major source of unrestricted funds.
Grants Administration: The streamlining of many grant
administration practices, some developed through university
and agency cooperation utilizing the Federal Demonstration
Partnership, has greatly improved the cooperative nature of
the partnership. However, we are concerned that streamlining
efforts not become “research pricing” policies, either overtly
or through practice. We have voiced such concerns about
the NIH modular grant program. For example, we would
strongly oppose any effort to implement a flat facilities
and administration rate on such grants in the guise of simplification.
Federally-Mandated Changes in University Business Practices
While we agree with much of the report’s discussion of federally-mandated
changes in university business practices, this section of
the report fails to recognize the burdens state and local
regulations may place on the federal-university research relationship.
We believe there needs to be a focused federal effort to coordinate
policies among various regulatory entities, be they federal,
state, or local. For example, the proposal to hold a
forum on best practices in environmental protection in research
laboratory settings is a good one. However, it must involve
state-, county-, and local-level officials if it is to be
effective.
We are particularly pleased with the proposal to establish
more effective mechanisms to review government business policies
and practices. The recommendation’s emphasis that these
practices should be reviewed to “consider their relationship
to each other, assess their impact on research, and determine
their compatibility with university processes” is especially
critical. Federally-sponsored research at universities
is not a relationship of procurement, but rather is a shared
investment by both the university and the sponsoring agency
in our nation’s future well-being.
We reiterate our satisfaction that the NSTC’s report makes
meaningful and constructive progress in addressing the issues
facing the federal-university research partnership.
Society has benefited tremendously from this historic relationship,
which has produced unprecedented new scientific knowledge
that has improved both the quality and length of life and
contributed enormously to America's economic prosperity.
Only by working together can we ensure that the partnership
will continue to flourish in the 21st century. The NSTC
report has provided us with an excellent blueprint to strengthen
the relationship for the challenges ahead.
Sincerely,
Jordan J. Cohen, M.D.
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