November 6, 2003

Dr. Michael Holland

Office of Science and Technology Policy

1650 Pennsylvania Avenue, N.W.

Washington, D.C. 20502

Dear Dr. Holland,

Grinnell College is deeply committed to the education of undergraduates
who may subsequently join the ranks of science educators, the STEM
workforce, and scientifically literate citizens. While only 8% of
undergraduates enrolled at 4-year colleges are enrolled in liberal arts
colleges like ours, these colleges produce 17% of the graduates who go
on to earn Ph.D.s in the sciences. It is important that Federal
regulations and practices consider the unique features of these
institutions so as to facilitate the tremendous work in the sciences
these institutions do.

With regard to the work of the Subcommittee on Research Business Models,
we would like to make these comments, outlined in accordance with the
topics suggested by the information in the Federal Register, August 6,
2003.

A.  [Accountability]{.underline}. Faculty at Grinnell College conduct a
    variety of basic research programs. They are highly accountable
    within the institution and to professional peers. By comparison,
    methods of accounting to the government (e.g., via grant reporting)
    are often redundant and, because of awkward formats and limited
    online space, place an emphasis on the reporting of objects and
    artifacts while underemphasizing other significant accomplishments
    -- the education of students who will go on to have STEM careers and
    the general education of others who will be able to understand
    important scientific issues. The broader concept of accountability
    should be modified to fit undergraduate institutions.

B.  [Inconsistency of policies and practices among Federal
    agencies]{.underline}. Scientific research regulation may be quite
    different at various types of educational institutions. Liberal arts
    colleges approach record-keeping and oversight responsibilities from
    a different perspective than large research universities. Research
    universities often have freestanding offices responsible for
    creating and responding to paperwork and oversight responsibilities
    for their faculty involved in research. Small liberal arts colleges
    do not have the resources to commit to such stand alone offices.
    Thus, the burden of compliance falls unequally. The lack of
    resources, combined with the differing compliance requirements
    across Federal agencies (e.g., how the USDA, the Public Health
    Service, and NIH interpret the laws regarding laboratory animal
    welfare), are burdensome to small institutions when compared to the
    limited scope and scale of the research programs.

C.  [Inconsistency of policies and practices among
    universities]{.underline}. This issue only comes into play in the
    administration of subrecipient agreements between our small and
    highly efficient grants management system and that of large research
    universities which have a highly stratified and procedure-driven
    systems of grant administration. In these cases, we have been able
    to adapt on a case-by-case basis to meet the needs of the large
    university system.

D.  [State and Institutional requirements]{.underline}. We are fortunate
    to have little state regulatory interference in the administration
    and oversight of our research activities.

E.  [Regulatory requirements]{.underline}. Because scientific research
    regulation can and should vary for different types of educational
    institutions, we encourage the Federal agencies to convene a small
    group of faculty and administrators from baccalaureate degree
    institutions, including the liberal arts colleges and ask the group
    to streamline compliance data collection and reporting requirements.
    Grinnell College would be pleased to offer the services of a senior
    faculty member and administrator involved in institutional
    compliance for this purpose.

F.  [Research support]{.underline}. We believe it is essential that
    federal support for undergraduate research experiences takes into
    account the differences in which undergraduate STEM education is
    undertaken by research universities and liberal arts colleges.
    Undergraduate research experiences at large research universities
    may include layers of personnel between the faculty mentor and the
    undergraduate student (e.g., graduate students); highly structured
    and personnel-intensive activities such as seminars and workshops;
    and a relatively diminished emphasis on the student learning
    experience. Undergraduate research experiences at liberal arts
    colleges include direct working relationships between undergraduates
    and faculty mentors; informal and implicitly modelled teaching by
    the mentor; and a central focus on student learning. Neither
    approach is necessarily superior. It is necessary, however, for
    funders to understand the differences as they make decisions about
    funding programs that improve the student\'s scientific thinking,
    career planning, and eligibility for graduate education. In view of
    these significant differences in approach to undergraduate student
    learning resulting from research experiences we would encourage
    Federal funding agencies to revise the grant review criteria to
    target the central elements of these pedagogies.

G.  [Multidisciplinary/collaborative research]{.underline}. Faculty at
    liberal arts colleges like Grinnell need to have multiple
    opportunities for research collaboration with colleagues working on
    similar problems in their field and in fields which are
    complementary at institutions of all types across the country and
    overseas. These opportunities (similar to the NSF ROA) should range
    from a few weeks or months in a colleague's laboratory to longer
    periods devoted to acquisition of a particular research technique to
    utilization of a specialized instrument or suite of instruments. We
    believe that this is an extremely cost-effective and efficient
    method of accommodating the research needs of our faculty by
    avoiding the need for instrument acquisition and maintenance and by
    affording faculty, who in our small departments typically are the
    only one working in the discipline, a brief collaboration outside
    the institution. We would hope to see Federal agencies significantly
    increase the funding for and reduce the competitive requirements for
    these types of special research collaborations.

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H.  [Research Infrastructure]{.underline}. Infrastructure makes a
    difference in the learning paradigm, including the interactions
    between student and faculty, and student and student.  A well
    designed building promotes a creative community, whether the student
    experiences one science course on the way to becoming a
    scientifically literate citizen or multiple courses and research on
    the way to becoming a professional scientist. Facilities planning is
    a difficult and complex task. It stimulates the best kinds of
    institutional thought and planning. The now defunct NSF program
    which supported research facilities modernization served to
    stimulate much planning.  Many proposals funded resulted in projects
    where Federal funds were highly leveraged, with much more
    non-Federal funding than NSF funding.  Other proposals submitted and
    not funded ultimately resulted in completed projects as the NSF
    program served as a stimulus for the creation of practical and
    defensible plans that were often funded by other sources. We highly
    encourage Congress and the national scientific funding agencies to
    recommit to widespread investment in the nation's scientific
    infrastructure.

I.  [Information technology]{.underline}. We applaud the laborious
    efforts of the NSF in developing a highly effective grant proposal
    and grant management system- FastLane. We note that many government
    agencies which fund research in disciplines across the board are now
    shifting to on-line submission of proposals and reports. We strongly
    believe that development of differing systems is not cost-effective
    and in fact decreases productivity and efficiency in research
    administration and believe that interface uniformity, to the extent
    possible, should be encouraged.

J.  [Technology transfer optimization]{.underline}. We continue to
    support the provisions of Bayh-Dole and believe that its provisions
    have been instrumental in sustaining the progress to date in
    technology transfer.

We look forward to hearing more about the work of the Subcommittee and
would welcome additional dialogue on these topics. If you have any
questions or wish to receive more detailed information on any of these
issues, please contact me at (641) 269-3000 or by email at
<osgood@grinnell.edu>.

Sincerely,

Russell K. Osgood