United States General Accounting Office

GAO Report to Congressional Requesters

September 1995 FEDERALLY FUNDED

R&D CENTERS

Use of Contract Fee by

The Aerospace

Corporation

GAO/NSIAD-95-174

GAO United States

General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-259377 

September 28, 1995

The Honorable Bill Zeliff

Chairman

The Honorable Karen L. Thurman

Ranking Minority Member

Subcommittee on National Security,

 International Affairs, and Criminal Justice

Committee on Government Reform and Oversight

House of Representatives

As requested by the former Chairman and Ranking Minority Member, we

reviewed how The Aerospace Corporation used a $15.5 million contract

fee provided by the Air Force in fiscal year 1993 to operate a federally

funded research and development center (FFRDC). We also reviewed the

regulatory requirements governing the determination and use of this fee.

This is our second report on Aerospace. Our first report addressed

executive compensation, as requested.1

Results in Brief Aerospace spent $11.5 million, or 74 percent, of its $15.5 million fee for

research. It spent the remaining $4 million for capital equipment

purchases, real and leasehold property improvements, and unreimbursed

expenses.

Even though the Air Force and Aerospace discuss Aerospace’s specific fee

needs and intended use as a basis for fee award, the contract contains the

total fee amount. Once the Air Force awards the fee, Aerospace exercises

some discretion over how to spend it and other sources of corporate

funds, such as interest income and fee from other contracts. The manner

in which Aerospace spends its corporate funds in a given year can affect

how much Air Force fee is needed in the following year.

In May 1995, the Department of Defense (DOD) issued a report to the

Congress on fee management at defense FFRDCs. The report focused on

ways to limit the use of fee. It recommended, among other things, that

(1) defense FFRDC fee amounts be based on the contracting officer’s

determination of fee need and not on the application of weighted

guidelines,2

 (2) all allowable and allocable costs be moved from fee to the

1

Federally Funded R&D Centers: Executive Compensation at The Aerospace Corporation

(GAO/NSIAD-95-75, Feb. 7, 1995).

2

These guidelines focus on performance risk, contract type, and facilities capital employed.

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cost reimbursement portion of the contract, and (3) guidance be

developed regarding what costs are to be considered ordinary and

necessary to the operation of an FFRDC. DOD has indicated that it is working

to improve the fee management process based on these recommendations,

as well as the most recent GAO and DOD Inspector General work on this

issue.

Background FFRDCs are private sector organizations funded primarily by federal

agencies to meet a special long-term research and development need that

cannot be met as effectively by existing in-house or contractor resources.

One federal agency serves as the primary sponsor of the FFRDC and signs

an agreement specifying the purpose, terms, and other provisions for the

FFRDC’s existence. Agreement terms cannot exceed 5 years but can be

extended after a review by the sponsor of the continued use and need for

the FFRDC. Federal regulations state that an FFRDC is required to conduct its

business in a manner befitting its special relationship with the

government, operate in the public interest with objectivity and

independence, be free from organizational conflicts of interest, and have

full disclosure of its affairs to the sponsoring agency.

The Aerospace Corporation is a private, nonprofit mutual benefit

corporation created in 1960. Aerospace’s primary purpose is to provide

scientific and engineering support for the U.S. military space program.

Aerospace operates an FFRDC in support of U.S. national security space

programs pursuant to the Federal Acquisition Regulation (FAR), and its

primary sponsor is the Air Force. Aerospace is governed by a 16-member

Board of Trustees in accordance with its articles of incorporation and

bylaws.

The Air Force Space and Missile Systems Center (SMC), a part of the Air

Force Materiel Command, has day-to-day management responsibility over

the FFRDC. Through fiscal year 1994, SMC negotiated annual

cost-plus-fixed-fee contracts with Aerospace. In fiscal year 1995, it began

operating under a cost-plus-award-fee contract where the amount of fee is

based on Aerospace’s performance. Table 1 shows the contract costs and

fees awarded to Aerospace between fiscal years 1989 and 1994.

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Table 1: Air Force Contract Costs and

Fees With Aerospace Between 1989

and 1994

Dollars in millions

Fiscal year Contract costs Fee

1989 $371.4 $19.0

1990 389.8 20.5

1991 375.6 19.9

1992 373.5 16.8

1993 401.7 15.5

1994 355.4 15.6

Although SMC is the primary customer, Aerospace also performs work for

other U.S. government agencies, international organizations, and foreign

governments. In fiscal year 1993, for example, Aerospace’s reported

revenues totaled $422.2 million, of which 97.4 percent came from the Air

Force and other DOD agencies; 2.2 percent from other federal agencies,

such as the National Aeronautics and Space Administration; and

0.4 percent from nonfederal government sources, such as universities and

foreign governments.

Regulatory

Requirements on

FFRDC Fee

The Office of Federal Procurement Policy Letter 84-1, dated April 1984,

established governmentwide policies for the establishment, use, review,

and termination of the sponsorship of FFRDCs. It provides that the

conditions affecting the negotiation of fee should be identified in the

contract, sponsoring agreement with the FFRDC, or the sponsoring agency’s

policies and procedures, as appropriate.

The FAR also requires that the sponsoring agreement or the sponsoring

agency’s policies and procedures identify the considerations that will

affect the negotiation of fee when fee is determined to be appropriate. The

Defense Acquisition Regulation Supplement (DFARS) provides more

specific guidance for determining whether a fee is appropriate and how

the fee is to be determined. Since FFRDCs may incur expenses that are

unreimbursable under federal regulations, the DFARS allows for a fee to

cover unreimbursed expenses if they are deemed ordinary and necessary

to the FFRDC. An SMC contracting office instruction provides the fee

determination procedures to be used on the Aerospace contract. It states

that the fee is to be based on a need that must be justified and that the fee

must be used for the purposes awarded.

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Aerospace’s Use of

Fee

In fiscal year 1993, Aerospace reported that it used about $11.5 million of

the $15.5 million Air Force contract fee to sponsor research. It used the

remainder of the fee, along with other corporate resources, for capital

equipment purchases, real and leasehold property improvements, and

other unreimbursed expenditures.

According to Aerospace officials, the fee from Air Force contracts is

combined with funds from other sources in Aerospace’s accounting

records. Therefore, it is not possible to link each specific use of

Aerospace’s funds to the specific funding source. However, Aerospace and

SMC have a general understanding that sponsored research is to be paid

from the Air Force contract fee. Also, the accounting standards and

principles governing Aerospace do not require it to match funding use with

funding source. Table 2 shows Aerospace’s actual sources and

applications of funds in fiscal year 1993.

Table 2: Sources and Applications of

Funds at Aerospace for Fiscal Year

1993

Sources of funds Amount

Air Force contract fee $15.5

Equipment depreciation 13.5

Leasehold amortization 1.0

Interest income 0.9

Working capital change 0.4

Other contract fees 0.2

Total $31.5

Applications of funds

Research $11.5

Capital equipment 14.3

Real and leasehold property improvements 3.8

Unreimbursed expenses 1.9

Total $31.5

Research Aerospace used the Air Force fee primarily to sponsor research with

broader and longer term goals than the more immediate, direct goals of

individual Air Force program offices. In fiscal year 1993, Aerospace spent

about $11.5 million, or 74 percent, of the Air Force fee for sponsored

research.

According to Aerospace officials, these funds were used for research in

such areas as electronic device technology, surveillance, and information

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B-259377 

sciences. They added that sponsored research has resulted in cost savings

for the Air Force space program. For example, Aerospace attributed to

such research a 50-percent increase in the life expectancy of satellite

sensors in the Defense Meteorological Satellite Program. It credited such

research with developing remedial procedures to extend the life of

satellite batteries, which have historically contributed to limiting the life of

the satellite. Aerospace also cited many other research benefits, such as

combining missions on a single spacecraft system and using commercial

parts and techniques.

One long-standing FFRDC issue has been whether to fund sponsored

research as a cost-reimbursable item or out of fee. A 1962 report to the

President on government contracting for research and development,

known as the Bell report, supported the continuation of fee payments for

research because most nonprofit organizations must conduct some

independent, self-initiated research if they are to attract and retain staff.3

On the other hand, an August 1965 congressional report on Aerospace

noted that some research would normally be a reimbursable expense and

therefore all of the research could be provided under reimbursement.4

Similarly, in December 1994, the DOD Inspector General concluded that

FFRDC-sponsored research should be reimbursed as contract costs to the

extent that is allowable and reasonable.5

 Most recently, in May 1995, a DOD

study, completed at the direction of the Congress, focused on ways to limit

the use of fee. It recommended that all allowable and allocable costs,

including research, be considered as reimbursable costs rather than paid

from fee.6

Although Aerospace believes that either funding approach is correct, it

believes that research is best funded using fee rather than being

reimbursed as a cost item. It said that making research a

cost-reimbursable item would decrease the responsibility of Aerospace

management and the Board of Trustees over independent research and

increase administrative burden. Also, Aerospace expressed concern that

Air Force program managers may not want to fund certain research

3

Government Contracting for Research and Development, Bureau of the Budget, April 1962.

4

The Aerospace Corporation: A Study of Fiscal and Management Policy and Control, Report of the

Subcommittee for Special Investigations, Committee on Armed Services, House of Representatives,

August 12, 1965.

5

Contracting Practices for the Use and Operations of DOD-Sponsored Federally Funded Research and

Development Centers, Audit Report No. 95-048, DOD Inspector General, December 2, 1994.

6

Comprehensive Review of the Department of Defense’s Fee-Granting Process for Federally Funded

Research and Development Centers, Department of Defense, May 1, 1995.

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B-259377 

because these managers may have more immediate goals than those for

Aerospace’s research program. Air Force officials said they acknowledged

Aerospace’s expertise and plan to use it to the maximum extent possible

regardless of the funding mechanism.

Reimbursing research as a cost item would not necessarily reduce total Air

Force contract costs, according to DOD. However, it would subject all

research to the FAR cost principles applicable to cost-reimbursable items.

Regardless of how Aerospace’s research program is funded, Air Force and

Aerospace officials acknowledged that the program’s effectiveness in

meeting Air Force needs could be improved. Air Force officials said that

the benefits from research could be increased by strengthening Air Force

and Aerospace coordination on project selection. According to Aerospace,

the effectiveness of the program will be improved as a result of recent

steps taken to improve the research selection process. These include (1) a

formal collection of prioritized Air Force Technology Need Statements,

(2) Air Force participation on Aerospace’s Technical Program Committee,

and (3) a formal briefing by Aerospace to the Air Force demonstrating the

relationship between selected research projects and the Air Force’s

prioritized technology needs.

Capital Equipment and

Real and Leasehold

Property Improvements

In fiscal year 1993, Aerospace spent $18.1 million of its working capital

funds for capital equipment ($14.3 million) and for real and leased

property improvements ($3.8 million). Aerospace officials said these

expenditures were funded from reimbursements for depreciation and

amortization ($14.5 million) and the Air Force contract fee ($3.6 million).

The FAR allows as reimbursable costs depreciation of capital equipment

and amortization of real property and leasehold improvements.

SMC defines capital equipment as an asset that has an estimated useful life

of over 2 years and a cost of $1,500 or more. It includes those items that

Aerospace generally uses to support Air Force contracts but are not

purchased in direct support of an individual project, such as computer

hardware and bundled software and laboratory diagnostic and test tools.

Capital equipment used in direct support of an individual Air Force project

is charged as other direct costs in the year acquired rather than

depreciated. DOD’s May 1995 report to the Congress recommended

requiring FFRDCs to submit an annual 5-year capital acquisition plan.

According to Aerospace, such a plan may be impracticable due to rapid

changes in personnel, technology, and equipment.

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Real and leasehold property improvements include building rehabilitation

projects, building equipment replacement, security and safety

requirements, new operational requirements, and seismic upgrades to

meet earthquake protection standards. On the Aerospace contract,

leasehold amortization has been a reimbursable cost, whereas building

depreciation has been funded primarily through the Air Force contract fee

and other corporate funds.

Unreimbursed Expenses In fiscal year 1993, Aerospace spent $1.9 million from fee and other

corporate funds on unreimbursed costs, that it considered ordinary and

necessary to the FFRDC. Some of these expenses were for contributions,

travel in excess of per diem, spouse and guest meals, personal use of

company-furnished automobiles, and advertising. Table 3 summarizes

Aerospace’s unreimbursed expenditures in fiscal year 1993.

Table 3: Aerospace’s Unreimbursed

Expenses for Fiscal Year 1993 Unreimbursed expense Amount

New business $521,500

Contributions 562,000

Miscellaneous 308,000

Travel in excess of per diem 76,000

Interest expense 22,000

Sundry 422,000

Total $1,911,500

New Business According to Aerospace officials, new business expenses are incurred to

broaden Aerospace’s involvement in non-DOD business to provide

employment and operational stability for Aerospace during periods of

declining DOD budgets. The officials said more non-DOD business was

needed because it has been impossible for Aerospace to maintain

employment stability in an environment of budget ceilings and reduced

DOD funding. Further, they said that broadening the corporation’s non-DOD

business base helps slow attrition and retain the skills and capabilities

needed to support the Air Force’s space mission. Aerospace noted that

employment has declined by 27 percent since 1990. Aerospace believes

that inadequate staffing levels could increase the risk of an expensive

program failure, which could lead to a serious degradation of national

security readiness. Aerospace also said a broader business base also

reduces the overhead costs allocated to Air Force contracts. According to

Aerospace, the precedent for new business development was set in the

late 1960s. At the time, DOD encouraged FFRDCs to make their services

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available to other government agencies so that they would transfer their

technical expertise to the civilian sector.

SMC officials recognize the benefits of new business development expenses

in retaining Aerospace’s core capabilities and reducing overhead costs. As

a result, the officials said they negotiated reasonable and cost-effective

limits on new business expenses in the contracts with Aerospace. For

example, they agreed to provide $400,000 for cost-reimbursable, new

business expenses in fiscal year 1993. The officials said they made clear to

Aerospace that any new business expenses in excess of the contract limit

were not reimbursable and could not be charged to the Air Force contract

fee. However, such restrictions were not expressly incorporated into

Aerospace’s contract.

In addition to the $400,000, Aerospace spent $551,500 on new business

expenses. Aerospace officials said that $521,500 came from corporate

funds other than the Air Force contract fee and $30,000 was charged

directly to other contracts. Table 4 shows the new business expenses

incurred by Aerospace during fiscal years 1990 through 1994.

Table 4: Aerospace New Business

Expense for Fiscal Years 1990

Through 1994

Fiscal year

Cost-reimbursable

limits

Additional amount

paid from other

fund sources Total

1990 $46,800 $7,800 $54,600

1991 85,000 0 59,800

1992 106,000 211,100 317,100

1993 400,000 551,500 951,500

1994 1,200,000 244,900 1,444,900

Total $1,837,800 $1,015,300 $2,827,900

For fiscal year 1995, Aerospace proposed $2.5 million in cost-reimbursable

new business expenses and $400,000 for bid and proposal expenses.

Aerospace officials said that allocating about 1 percent of its contracts’

value for new business was not unreasonable given the continued

reduction in budget ceilings; the government’s commitment in the

sponsoring agreement to a special, long-term relationship; and the

avoidance of costs associated with potential reductions in force. SMC

officials said they negotiated into the contract a cost-reimbursable amount

of $1.2 million for both new business expenses and bid and proposal

expenses, which they believed was an appropriate amount for the

anticipated benefits to the Air Force. Air Force Headquarters officials

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indicate that they intend to tightly control all non-FFRDC/non-DOD business

activities of Aerospace.

Contributions Aerospace officials said contributions help in hiring quality employees,

advancing affirmative action goals, and maintaining favorable

relationships within the community. Major cash contributions were

broadly categorized as either “community affairs participation” or “gift

matching program,” and Aerospace spent $307,000 and $255,000 for these

categories, respectively, in fiscal year 1993. Under the FAR, contributions

generally are not reimbursable costs. Accordingly, Aerospace’s

contributions were not reimbursed as cost items but were funded from its

corporate funds, which included the Air Force fee. Aerospace officials said

contributions were ordinary and necessary business expenditures that

were fully disclosed to the Air Force.

As a result of restrictions on charitable contributions contained in the

fiscal year 1995 National Defense Authorization Act, Aerospace and SMC

agreed that Aerospace would not make any further charitable

contributions from funds obtained from DOD. This agreement was

incorporated in the fiscal year 1995 contract.

Miscellaneous Miscellaneous expenditures from corporate funds totaled $308,000 for

fiscal year 1993 and included $58,700 for the personal use of company

cars, $143,100 for conference meals and trustee expenses, and $106,200 for

other expenses.

Aerospace corporate officers were provided company cars. The FAR states

that the costs of automobiles owned or leased by the contractor are

allowable if they are reasonable and the cars are used for company

business. Costs relating to the personal use of vehicles by employees

(including transportation to and from work) are unallowable. According to

Aerospace, the $58,700 charged to corporate funds for the personal use of

company cars was primarily for transportation to and from work and was

reported as taxable employee income.

Unreimbursed conference meals and trustee expenses of $143,100 in fiscal

year 1993 included unallowable costs, such as meals for spouses and

guests, that were incurred at trustee and other meetings. For example,

Aerospace included unreimbursed costs of over $4,000 for 36 spouses and

guests at the Collier Award banquet for the Air Force/industry team that

developed the Global Positioning System, of which Aerospace was a key

member. Aerospace said these unreimbursed expenses of $143,100 were

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ordinary and necessary. Similar expenditures also were incurred in fiscal

year 1994, including bar charges of $1,764 for 63 people, at a dinner

reception during a trustee meeting in March 1994.

Aerospace also incurred $106,200 for other miscellaneous expenditures in

fiscal year 1993 that included advertising, employee recreation activities,

and donations of capital equipment.

Travel in Excess of Per Diem Aerospace said travel expenditures in excess of per diem rates included

$25,000 for airline coupons used to provide business and first-class

upgrades for its corporate officers. Under the FAR, airfare costs in excess

of the lowest customary standard coach or equivalent airfare offered

during normal business hours are generally unallowable for cost

reimbursement. Accordingly, Aerospace did not submit the costs of

upgrades as cost-reimbursable items, although it obtained SMC approval in

1992 to upgrade to business-class air accommodations for corporate

officers on trips longer than 2 hours. SMC accepted Aerospace’s

justification that these upgrades would enhance officers’ productivity. SMC

officials said they might need to reevaluate whether airline upgrades

should be cost-reimbursable items due to DOD’s study to limit fee and new

federal guidelines on travel costs.

Interest Expense Interest expense at Aerospace amounted to $22,000 in fiscal year 1993.

Although neither the FAR nor DFARS specifically defines what are ordinary

and necessary expenses for FFRDCs, the contract operating instruction at

SMC cites interest expense as an example of an unallowable but ordinary

and necessary cost of FFRDC operations.

Sundry For purposes of this report, sundry includes $422,000 in costs for

(1) certain executive salary and benefits, (2) relocation and special

recruiting expenses, (3) achievement awards, (4) educational assignments,

and (5) bids and proposals. According to Aerospace, some of these costs

are allowable for cost reimbursement under the FAR. However, Aerospace

said it paid the costs out of corporate funds to avoid potential

controversies with the Air Force or the Defense Contract Audit Agency

regarding the costs’ allowability. For example, through fiscal year 1993,

Aerospace charged to corporate funds the portion of the president/chief

executive officer’s salary that exceeded the salary for Executive Schedule

Level II. Aerospace said it charged the president/chief executive officer’s

entire salary as a cost-reimbursable item in fiscal year 1994.

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Aerospace’s

Discretion Over Use

of Fee

Existing federal regulations provide general guidance regarding how fee is

to be determined, but do not restrict how a fee may be used nor define

what are ordinary and necessary expenses. Further, neither the Air Force

sponsoring agreement with Aerospace nor the annual contract specify

how a fee may be used. Although the Air Force and Aerospace discuss

Aerospace’s need for fee and planned use of fee by cost category,

Aerospace exercises some discretion in spending the fee and determining

what expenditures funded from fee are ordinary and necessary. Since

Aerospace’s fee is based on its need, the manner in which Aerospace uses

its corporate resources, including fee, in any one year may affect its need

for an Air Force fee in the following year.

Aerospace stated that even though it has discretion regarding the use of all

corporate resources, including Air Force fee, it attempts to use the

resources in a manner that is consistent with the plan presented to the Air

Force. Aerospace officials told us they recognize that if Aerospace used its

resources in a manner that was inconsistent with the plan discussed with

the Air Force, the Air Force might attempt to negotiate a reduced fee in

subsequent years. In this regard, Air Force officials told us Aerospace has

an inherent responsibility to spend its fee in accordance with the

justification of its need, even though it is not specifically required by the

contract to do so.

Inadequate Definition

of Ordinary and

Necessary Expenses

In establishing the fee provided to defense FFRDCs, the DFARS says that

consideration should be given to funding unreimbursed costs deemed

ordinary and necessary to the FFRDC. DOD’s May 1995 report on FFRDC fee

management recognized that the guidance in the FAR and DFARS concerning

the granting of FFRDC fees is not clear about what unreimbursed costs are

considered ordinary and necessary to FFRDC operations. The report

recommended that new guidance be developed and that the use of the

undefined and ambiguous term “ordinary and necessary” be avoided. The

report also recognized the need for specific examples of appropriate fee

use.

Implementing this recommendation should provide the Air Force with a

better basis for negotiating fee award. An agreed-upon definition of

ordinary and necessary expenses would assist contracting officers in

resolving issues with other defense FFRDCs. However, as long as moneys

provided through Air Force fee are commingled with other funding

sources, the Air Force may have difficulty determining how Aerospace

used its FFRDC fee.

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DOD and Aerospace

Comments

In commenting on a draft of this report, DOD stated that it did not dispute

the facts contained in the report and indicated that the report would be

helpful in the ongoing DOD efforts to strengthen FFRDC oversight and use of

management fees. However, DOD said that none of the data in the report

represented improper or illegal activity, as defined by existing statute or

regulation, on the part of DOD or Aerospace.

DOD further commented that it was taking positive steps to improve its

FFRDC fee management process. For example, it said that in the fiscal year

1996 Aerospace contract, the Air Force would address specific uses of fee,

such as personal use of cars and travel-related items, through contract

provisions or by disallowing the expense. Further, DOD said it was actively

working to improve the fee management process based on the findings

and recommendations made in DOD’s May 1995 report on fee management,

as well as work done by us and the DOD Inspector General. DOD’s

comments are included in their entirety in appendix I.

Aerospace provided specific language clarifications. These changes were

incorporated where appropriate.

Scope and

Methodology

We examined Aerospace’s proposed fee expenditures and the Air Force’s

and Defense Contract Audit Agency’s evaluations of Aerospace’s

proposals, including audit reports, supporting workpapers, technical

evaluations, and Air Force’s price negotiation memorandums. We also

examined documentation supporting the nature and purpose of selected

actual fee expenditures. Further, we obtained the views of Aerospace’s

officials and cognizant Defense Contract Audit Agency and Air Force

program and contracting officials at Aerospace on factors affecting the use

of fee.

To determine the regulatory requirements governing the determination

and use of fee, we reviewed applicable Office of Federal Procurement

Policy guidance; FAR and DFARS provisions; Air Force operating

instructions and procedures; and Air Force correspondence, contracts,

and sponsoring agreement with Aerospace. We reviewed Aerospace’s use

of fee for fiscal year 1993 because, at the time we began our work, it was

the most recently completed year for which Aerospace had submitted its

schedule of unreimbursed expenditures.

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We also exchanged information with DOD staff involved in the

congressionally mandated DOD study on FFRDC fees during their study of

the current fee determination process and fee management issues.

We conducted our work from October 1994 to July 1995 in accordance

with generally accepted government auditing standards.

Unless you publicly announce its contents earlier, we plan no further

distribution of this report until 30 days from its issue date. At that time, we

will send copies to the Secretary of Defense; the Director, Office of

Management and Budget; the Administrator, Office of Federal

Procurement Policy; and other interested congressional committees.

Copies will also be available to others upon request.

Please contact me at (202) 512-4587 if you or your staff have any questions

concerning this report. Major contributors to this report are listed in

appendix II.

David E. Cooper

Director, Acquisition Policy, Technology,

 and Competitiveness Issues

Page 13 GAO/NSIAD-95-174 Federally Funded R&D Centers
Appendix I 

Comments From the Department of Defense

Page 14 GAO/NSIAD-95-174 Federally Funded R&D Centers
Appendix I 

Comments From the Department of Defense

Page 15 GAO/NSIAD-95-174 Federally Funded R&D Centers
Appendix II 

Major Contributors to This Report

National Security and

International Affairs

Division, Washington,

D.C.

Charles W. Thompson

Office of the General

Counsel

Ernie E. Jackson

Los Angeles Field

Office

Odi Cuero

Benjamin H. Mannen

Amborse A. McGraw

(705086) Page 16 GAO/NSIAD-95-174 Federally Funded R&D Centers
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