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1. GUIDING PRINCIPLES
2. OPERATING PRINCIPLES
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 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 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 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.
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 possible.
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 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.
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.
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