December 11, 2003

Dr. Michael Holland

Office of Science and Technology Policy

1650 Pennsylvania Ave., N.W.

Washington, D.C. 20502

Dear Dr. Holland:

Illinois Wesleyan University 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 four-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 make possible the dynamic work in the sciences
done by these institutions.

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 members at Illinois Wesleyan
    conduct a variety of basic research programs both individually and
    with undergraduate students. They are highly accountable within the
    institution and to professional peers. By comparison, methods of
    accounting to the government, primarily for grant award 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. It seems appropriate that
    the broader concept of accountability 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, such as 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 sub-recipient agreements between our small and
    highly efficient grants management system and that of large research
    universities that have stratified and procedure-driven systems of
    grant administration.

D.  [State and institutional requirements]{.underline}. We are fortunate
    to have minor state regulatory interference in the administration
    and oversight of our research activities. However, we are required
    to inform our \"State Point of Contact.\"

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.
    Illinois Wesleyan would be willing to offer an 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, usually a graduate student, and a minimal
    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 modeled teaching by the mentor; possibilities for
    co-authorship of research papers; and a central focus on student
    learning. Because of these differences, we encourage Federal funding
    agencies to revise the central elements of these varying pedagogies.

G.  [Multidisciplinary/collaborative research]{.underline}. Faculty at
    liberal arts colleges like Illinois Wesleyan need to have multiple
    opportunities for research collaboration with colleagues at
    institutions of all types, across the country and overseas, who are
    working on similar problems in their field and in fields which are
    complementary. These opportunities (similar to the NSF ROA and INT
    programs) might 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. We would hope that Federal agencies
    significantly increase the funding for these types of special
    research collaborations. At the same time, it is important to make
    the competitive requirements mesh with the liberal arts
    teacher-researcher-scholar.

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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 inspires 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
    strongly 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 efforts of the
    NSF in its development of a progressive and effective grant proposal
    and grant management system---FastLane. As government agencies that
    fund research in disciplines across the board shift to on-line
    electronic submission of proposals and reports, we encourage
    interface uniformity.

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 (309) 556-3151 or by email at
[president@iwu.edu](mailto:osgood@grinnell.edu).

Sincerely,

Janet M. McNew

Acting President

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