EMBARGO: This document has been prepared for submission Introduction Federally supported university research is conducted because it is in the public interest to do so. These activities represent a confluence of the purposes of the government and the universities. The central issue of difficulty in this relationship is accountability. The National Commission on Research has received views from several hundred participants and observers of the system of university research supported with federal funds. These individuals express the problem in widely varied terms. While no three statements will encompass all the views, the following attempts to capture the main themes. The problem for the public is to assure that the best research is produced and that public monies are not wasted. The problem for the government is to attain its program objectives and fulfill its stewardship responsibilities. The problem for the universities is to conduct research well, to avoid diversion of resources to meet unnecessary administrative requirements, and to protect the integrity of their operations. Both the universities and the government seek to maintain public confidence in their activities. The specific problems of the government include concerns over stewardship, criticism for intrusion, the resource allocation process, avoiding diversion of federal programs to general university support, and loss of public confidence. Specific problems for the universities include criticism for poor management, reduction of level of research, restrictions on flexibility, and, again, the loss of public confidence. In October 1978, the independent National Commission on Research began to review these problems of the government-university research relationship and to recommend improvements. In this study on accountability, the Commission received views from government and university officials, as well as interested parties in industry and private organizations. The Commission members and a small staff reviewed existing studies and documents on this issue. The full report on accountability is available by writing the Commission at 2600 Virginia Avenue, N.W., Suite 1003, Washington, D.C. 20037. In this abbreviated version prepared for publication in Science, we have presented in synoptic form the definitions of accountability, the areas of concern, and the origins and evidence of the problem. We then list the conclusions of the Commission and the principles by which the government and the universities might properly carry out accountability. The recommendations are presented in their complete form along with the majority of their explanatory material. Definitions and Mechanisms The Commission analyzed two principal forms of accountability: financial and administrative accountability, which focuses on evidence of financial propriety and regularity and compliance with administrative requirements; and scientific accountability, which focuses on achievement of results or progress toward objectives. As most federally funded research is in the fields of science, the term "scientific accountability" has been chosen; this form is also intended to include research efforts in the social sciences and in the humanities. Financial and administrative accountability has the goal of assuring that funds are spent within the terms of the research agreement, without diversion, fraud, or waste. It is implemented through expectations and requirements of the sponsor, incentives and reporting, checks and balances in the operating systems of both parties to the research agreement, and subsequent reviews of expenditures and operations. Scientific accountability is largely self-enforcing without government interaction. In the research community, peers play a major role in deciding what work will be supported, who shall carry out the work, and what is significant. Researchers also file technical reports on their activity with agency sponsors. In some areas, researchers' accountability to the public takes place through public participation in their activity and through lay membership on committees responsible for the planning and oversight of research. Areas of Concern Government audits of university activities have repeatedly cited documentation practices which auditors find inadequate. Government officials also contend that universities are inordinately slow in improving their financial management systems and that federal funds are sometimes diverted from one project to another or to unsponsored activities. Recent reports of the Department of HEW Inspector General and the General Accounting Office have detailed these difficulties. Although an audit finding does not necessarily mean a final disallowance after the subsequent steps of audit resolution are completed, the size and proportion of these difficulties indicate a lack of agreement about appropriate documentation standards. The universities contend that fraud and abuses are rare, without condoning their occasional occurrence. The universities point to an escalation of documentation standards which are unacceptable, and oppose their retroactive imposition. The universities chafe at what they believe to be an overemphasis on accounting precision which is meaningless. They believe it falsely engenders security. Increasing indirect cost rates are a concern to many, while university central administration officials lament spiraling energy costs and escalating administrative requirements which cause such increases. In his March 1979 science message, President Carter called for "renewed attention" to the partnership between universities and the government for research. Comptroller General Elmer Staats has acknowledged the strains in the partnership and suggested that steps be taken to ease them. Popular media have presented information on these problems, some of which has been out of context and without balance. Several congressional committees have introduced these topics into hearings and considered them in pending legislation. : Origins of the Problems The origins of the problems are deep-seated. They include process and organizational differences between universities and the government. There are also differences between university operations and private enterprise, where the application of fiscal and administrative accountability tools was principally developed. The character of research activity does not align with existing practice for measuring researchers' efforts. Institutions are highly diverse but must meet a uniform federal standară. The dominant research support distribution system of project grants is highly commendable, but does not fit the ongoing way that research is conducted. Finite periods of support do not relate to the continuous nature of research inquiries. Competition for scarce funds makes proposals increasingly specific, notwithstanding the great uncertainty of the research process. Rising indirect costs and the revision of federal principles which govern their reimbursement (OMB Circular A-21) leave many problems unsolved. These continuing disagreements derive primarily from the erosion of a mutual but largely unwritten understanding of the basic nature of the governmentuniversity relationship in support of research. Until this understanding is repaired, efforts to agree on a set of appropriate cost principles are futile. Evidence of the Problems The evidence that the discovery process is being undermined by requirements for fiscal and administrative accountability is largely descriptive and impressionistic. It is exceedingly difficult to document with precision the costs of lost opportunity, motivation, and morale. The Commission has interviewed many scientists and administrators from both the government and universities. It has reviewed previous studies by the government, private commissions, and independent commissions and associations. Congressional committees have received a significant body of testimony evidencing administrative problems of academic researchers caused by government reporting requirements. While the Commission believes that certain areas could merit further |