To: OSTP

From: Alexander Scheeline, Professor of Chemistry

Department of Chemistry

University of Illinois at Urbana-Champaign

600 S. Mathews Ave.

Urbana, IL 61801

scheelin@scs.uiuc.edu

\(217\) 333-2999

Re: NSTC Research Business Models Comments, Items A, B., E., and F.

Date: September 4, 2003

A.  Accountability

The ultimate accountability of the research enterprise is to the society
as a whole i.e. to the training of a technically-skilled workforce, the
generation of new ideas that will power the economy, and the improvement
of quality of life (a concept difficult to quantify). How can one show
accountability in the short run, when the goal is long-run? Current
practices show accountability that is easy to measure (bidding
practices, rationalized decisions on funding), but have no way to show
that the decisions are better than alternatives would have been. Here\'s
an experiment to consider: for some NSF or NIH initiative: fund some
number of grants by the usual process. Then randomly select the same
number of otherwise-to-be-declined grants and fund them. Wait 20 years.
Evaluate the impact of each set of grantees and their students. Did peer
review work? Only by funding the \"losing\" proposals can the foresight
presumed to work in the current proposal system be demonstrated.

The remainder of my comments in this section might equally well be
considered as part of comments in section F, Research Support.

In my field, chemistry, it is presumed that we need to encourage as many
students as possible to get Ph.D.s and then for previously
under-represented groups to join the professoriate. I have seen several
students choose not to go the academic route because of the difficulty
they perceive in funding their work. Consider that each year the US
grants approximately 2000 chemistry Ph.D.\'s (and has for at least the
last 20 years). That means that at any time, there are approximately
10,000 graduate students in chemistry departments in this country. To
provide a stipend, tuition, and minimal operating funds for every one of
them would cost \$30,000 per student per year (This year at Illinois, a
stipend is about \$18,000, tuition waiver is \$6,700, and a year\'s
chemicals etc. might cost \$5,000, for a total of \$30,000, excluding
indirect costs. With ICR, the cost would escalate to \$43,000 per
student per year). That means that an uncritical expenditure of
\$300,000,000 (without ICR) to \$430,000,000 (with ICR) would fund every
current student with NO proposals, NO paperwork, NO uncertainty on the
ability of a faculty member to support continuing students, and vastly
increased intellectual freedom. If one required students to be teaching
assistants for two years (common at many schools), the cost would drop
by \$98,000,000 (direct) or \$146,000,000 (including ICR). These figures
should be contrasted with the total funds currently finding their way to
chemistry students via NSF, NIH, DOE, and DOD. If the situation is
similar to what it was when I was a \"rotator\" at NSF in 1990-1991, it
will turn out that at NO extra cost to the taxpayers, all these students
could be funded. Where\'s the accountability?

1)  Faculty time previously spent writing dozens of proposals in the
    hope a few get funded would instead be focused on teaching students.

2)  People previously scared away from academia due to the uncertainty
    obtaining operating funds would no longer face this uncertainty.

3)  Freedom of inquiry for highly risky projects would increase,
    together with the likelihood that the wildly creative idea could
    root and grow.

4)  Collaboration would be influenced by neither funding bureaucracy nor
    university policy. It wouldn\'t matter who was on whose payroll.

5)  Universities would become far more \"family friendly.\" A problem
    pregnancy (for example) that currently would lead to missed proposal
    deadlines, funding interruptions, stymied students, and (possibly)
    destroyed careers would instead simply be a time away from the lab,
    with students still funded, still productive, and not threatened by
    economic disaster. What other change could have such a positive
    impact on the demographics of the academic workforce, or the quality
    of life for the entire scientific community?

The counterargument is obvious: without repeated oversight as provided
by peer-reviewed proposals (most of which are declined), second-rate
science might flourish to the detriment of first-rate science. I know of
no hard evidence that this would occur. Peer review of proposals is a
highly effective way to say \"no.\" It is a terrible way to say, \"it\'s
risky, it\'s different, it\'s creative, but YES.\" Perpetual oversight
makes the assumption that a highly-skilled, creative workforce is in
fact typically inept, in perpetual need of being blocked from being
counterproductive (by misspending public funds), and that peers are
better able to perceive the flaws in someone else\'s ideas than to
generate ideas of their own. Vast amounts of time and energy are spent
just trying to keep one\'s students in lab with even minimal resources.
Wouldn\'t we be better off with less oversight and less short-term
accountability, even with a few boondoggles, if, as a result, we had a
demographically better balanced workforce and greater creativity in an
atmosphere of free inquiry?

B.  Inconsistency of Policies and Practices Among Federal Agencies

The modular budget procedure at NIH acknowledges that the typical
proposal (80% of new proposals) will not be funded, and it is thus a
waste of time for researchers to justify a budget in detail that has
only 1 chance in 5 of ever having tangible effect. An approximate
indication of budget is necessary to adequately evaluate a proposal, but
detailed budgeting is typically not a significant factor in a funding
decision (in fact, do we want errors of a few dollars here or there to
be decisive in funding decisions? I think not.). The NSF model for
electronic submission of proposals, coupled to the NIH model of only
approximate budgeting until funds are likely to be forthcoming would be
a winning combination. Matching forms for Current and Pending Support,
Curriculum Vita and budgets among agencies would help, since it is
common for similar numbers and forms to apply to many simultaneous
proposals.

E.  Regulatory Requirements

Rather than requiring institutional certification of compliance to be
included with every proposal and a presumption of non-compliance made of
every principal investigator (lacking a signature to the contrary), why
not maintain a list of complying organizations and electronically stamp
\"in compliance\" on all proposals from that institution? A strong audit
of actual performance rather than signatures that simply slow down
proposal routing should insure accountability while cutting bureaucracy.
I recently had a proposal rejected in part because a certification of a
particular type of oversight wasn\'t included -- even though the
proposal stated that such oversight would be sought if necessary, and in
no case would the regulated work be carried out during the first two
years of a grant. The lack of a photocopied form, irrelevant to over 2/3
of the work, was used as a bureaucratic excuse (admittedly by reviewers,
not a federal agency directly) to shut down a project. Enforce
compliance? Of course. Use paperwork as a life-or-death decision on a
project? WHY? Who benefits? No one!

F. Research Support

A recent proposal declination said (slight paraphrase): the ideas are
creative, the track record is strong, not everything that is proposed
can be accomplished in 3 years, there are doubts about a few of the
sub-projects, there is insufficient preliminary data (despite the strong
track record in closely related areas), therefore don\'t fund. How is
one supposed to get preliminary data without funds? One frequently gets
the feeling that the proposal/funding game is Russian roulette, where
one is trying to hit a moving pinhole. At some point, productive people
should having funding in proportion to the number of students they can
convince to do research. Now, it\'s backward. Students gravitate to
funded groups. There is an aspect of self-organization at work. A large
group can stay funded if 25% of the students are productive. A small
group with any gap in productivity can become defunded and then, lacking
\"preliminary data\" have no way to restart. The typical research
budget, in the absence of a grant, is ZERO. One can do a lot with a
little, but nothing with nothing. Federal support should encourage
scientists to continually push back scientific and technical frontiers.
Current policies encourage them to write nearly unlimited numbers of
proposals. The toughest problem in science is NOT the science. It is
probably not the interpersonal issues of disparate collaborators. It is
keeping enough funds in the kitty to allow any work to happen. So long
as this is the case, only the super-aggressive will be attracted to
academic science. Is it demonstrated that aggressiveness, quality,
creativity, and productivity are correlated? Or is it that only
aggressive people can survive in the current system? Is such
aggressiveness the *sine qua non* for scientific excellence in industry?
If not, why should it be the pre-requisite to teaching (a helping
profession) in the University? In industry, proposals are turned around
in minutes (small money) to months (big money), usually a page or two as
bullet lists. In academia, a 15 page, carefully crafted, lavishly
illustrated masterwork of a proposal can take months to write, minutes
to shred intellectually, and nearly a year to turn around for a revised
request. In a world where most communication takes place in seconds,
proposal review occurs glacially, and any tiny fault can set back or
destroy an entire research program. If we funded people and
institutions, not projects, scientists would feel free to move from area
to area quickly and flexibly. The current system funds incrementalism
well, but makes field changes for mid-career scientists or mid-degree
students nearly impossible.