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1. GUIDING PRINCIPLES
Research is an investment in the future.
The linkage between research and education is vital.
Excellence is promoted when investments are guided by merit review.
Research must be conducted with integrity.
2. OPERATING PRINCIPLES
Agency cost sharing policies and practices must be transparent.
Partners should respect the merit review process.
Agencies and universities should manage research in a cost-efficient manner.
Accountability and accounting are not the same.
The benefits of simplicity in policies and practices
should be weighed against the costs.
Change should be justified by need and the process made transparent.
The following are guiding principles that govern interactions between the
Federal government and universities that perform research.
1. GUIDING PRINCIPLES
Government sponsorship of university researchincluding the capacity to perform
research and the training of the next generation of scientists and engineersis 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 integration of research and education is the hallmark and strength of our
nations 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 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.
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.
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 awardees institutions 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.
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.
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
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
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
uniformitys 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
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.