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statement of each principle.
1. GUIDING PRINCIPLES
2. OPERATING PRINCIPLES
The following are guiding principles that govern
interactions between the Federal government and universities that perform
1. GUIDING PRINCIPLES
- Research Is an Investment in the Future.
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 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
- 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
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
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
- 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.