[Okgrantsmanship] NSF Policy on Cost Sharing - Ending Voluntary Cost Sharing

[Mason, Linda]

INSIDE HIGHER EDUCATION 


Leveling the NSF Playing Field 


August 31, 2009 

Colleges and universities contribute significantly to the cost of
federally sponsored research projects, through what they spend on
research labs and equipment, faculty start-up packages, and "indirect"
costs that aren't reimbursed by the government. 

At various points, federal agencies have either required or encouraged
them to quite literally "share" the costs of research grants they win,
essentially putting up their own funds to match a portion of the grant's
value. The practice has been debated, though, with proponents arguing
that it shows institutions' commitment by forcing them to put their own
"skin in the game," but detractors saying that requiring or encouraging
"cost sharing" puts less-wealthy colleges and universities at a
disadvantage against wealthier peers, and can lead grant reviewers to
favor proposals from institutions that volunteer to contribute even
though that isn't supposed to factor into the decision making. 

The 2007 American COMPETES Act asked the National Science Board to weigh
the pros and cons in reassessing the cost sharing policies of the
National Science Foundation, and the board issued a report
<http://www.nsf.gov/pubs/2009/nsb0920/nsb0920_1.pdf>  Friday that calls
for ending the practice of "voluntary" cost sharing in all
circumstances, while continuing "mandatory" contributions in a small
number of industry-focused federal programs as recommended by an interim
report
<http://www.nsf.gov/nsb/publications/2008/rprt_congress_cs_policy.pdf>
the board issued last year.

"The board firmly believes that prohibiting voluntary committed cost
sharing, and permitting mandatory cost sharing requirements only in
limited and appropriate circumstances, will not reduce institutional
commitment and financial contributions to NSF-sponsored projects or
negatively impact institutional stewardship of Federal resources,"
Steven C. Beering, president emeritus of Purdue University and chairman
of the science board, wrote in a memo accompanying the report. "Instead,
it likely will enhance the ability of institutions to strategically and
flexibly plan, invest in, and conduct research projects and programs,
and will promote equity among grantee institutions in NSF funding
competitions."

The report, "Investing in the Future NSF Cost Sharing Policies for a
Robust Federal Research Enterprise," recounts the history of the science
foundation's policies on cost sharing, which has shifted repeatedly over
50 years <http://www.nsf.gov/pubs/2009/nsb0920/nsb0920_4.pdf> . In 2004,
the science board eliminated mandatory cost sharing requirements in all
NSF programs, aligning the agency's practices with those of other
federal research agencies. The change did not address "voluntary" cost
sharing, which continued to be permitted under NSF rules.

Eliminating required matching by institutions was designed to take an
institution's ability to contribute financially out of the peer review
equation and "remove eligibility barriers to participation in certain
NSF programs by institutions unable to provide the required cost
sharing," among other beneficial outcomes, the board writes in its new
report.

But the 2004 change created some problems, too, most notably that it
made it more difficult for colleges and universities to "leverage"
federal money to attract corporate research support in NSF programs that
are designed to encourage academic-industry collaboration.

When the panel on cost sharing began its work in late 2007, as demanded
by the America COMPETES Act, which was designed to strengthen the
country's commitment to research and education in the physical and
natural sciences, it very quickly reached the conclusion that the NSF
should alter its policies on mandatory cost sharing. Its February 2008
report recommended that the agency reinstate mandatory matching in three
programs with strong corporate involvement: the Experimental Program to
Stimulate Competitive Research, Industry/University Cooperative Research
Centers, and Engineering Research Centers programs (which NSF promptly
did).

The report issued Friday, based on a broader review and soliciting of
opinions on the NSF's cost sharing policies, affirms that the NSF should
"allow, but narrowly circumscribe, the application of mandatory cost
sharing requirements in NSF programs in which cost sharing is
foundational to achieve programmatic goals," which at this point it
defines as the programs above plus two programs in which it was dictated
by America COMPETES: the Major Research Instrumentation Program and the
Robert Noyce Teacher Scholarship Program.

The panel dedicates much more discussion, though, to the thornier issue
of "voluntary" cost sharing -- which like many other financial issues
gets complicated because it becomes something other than fully
"voluntary," because those that don't pony up often come to be seen
(fairly or not) as weaker by those making decisions.

"The proposer community generally views offers of voluntary committed
cost sharing in proposals in increasing their competitiveness (i.e.,
likelihood of receiving funding) in NSF funding competitions," the
science board writes. "Correspondingly, failing to offer significant
voluntary committed cost sharing in proposals is viewed as creating a
competitive disadvantage. These views are widespread and strong ... even
though NSF instructs program officers, reviewers, and the proposer
community that voluntary committed cost sharing is not to be a factor in
the merit review and award decision process."

The assessment that voluntary sharing creates inequity among research
institutions, combined with a desire to ease institutions'
administrative burdens for tracking voluntary cost sharing and to give
colleges and universities "maximum flexibility in expending their
discretionary resources on research activities," led the science board
to recommend that "NSF should prohibit voluntary committed cost sharing
in all components of both solicited and unsolicited proposals."

The science board report includes one further recommendation that could
bode well for colleges and universities down the road: a suggestion that
the federal government review whether to raise the cap (currently at 26
percent) on the percentage of administrative costs for which
universities can be reimbursed by the government on research projects.
Universities are alone among among contractors that do federal research
on which such a cap is imposed, the Council on Governmental Relations
notes <http://206.151.87.67/docs/OrszagLetterAdministrativeRelief.doc> .

"The board understands the fundamental intent of the administrative rate
reimbursement cap -- to ensure that the majority of research funding
supports direct research effort, rather than administrative costs -- but
also concurs with the general view of the research community that the
current 26 percent reimbursement cap requires re-evaluation," the report
states.

- Doug Lederman <mailto:doug.lederman at insidehighered.com>  

(c) Copyright 2009 Inside Higher Ed

 

 

Linda Mason, Ed.D.

Coordinator for Grant Writing and External Funding

Oklahoma State Regents for Higher Education

655 Research Parkway, Suite 200

Oklahoma City, OK 73104

405-225-9486

lmason at osrhe.edu

IP: 164.58.250.178

 

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