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COUNCIL 2001-2002 Year-end
Committee Reports
Research
Scheduled
for discussion at Council on October 2, 2002
During
the 2001-02 academic year the University Council Committee on Research
was charged with: (a) review of the Provost's study of the
cost of research to the University: (b) examine the cost in time
and resources to investigators in complying with regulatory requirements
in human and animal studies; and (c) review the revised University
policy for postdoctoral fellows. Additionally, the committee was
asked to advise the Vice Provost for Research on contracts that
potentially violate University guidelines described in The Faculty
Handbook. The Committee met six times with appropriate University
officials and their findings have been incorporated in this report.
A. Review
of the Provost's Analysis of the Cost of Research
to the University
During
the past year, the Provost's office completed an analysis of
the cost of doing research at Penn entitled: "Calculating the
Cost of Research." The purpose of the study was to determine
the cost of supporting externally funded research at the University
and to ascertain if indirect cost recovery (ICR) was sufficient
to offset these expenses. Costs for supporting research fall into
three categories: administration, facilities and utilities. Revenue
to support these functions are derived from ICR which the University
receives from most external research grants. The Provost's
study determined that a modified ICR rate required for the University
and Schools to meet their expenses for supporting research was 57.5%.
It is noteworthy that the calculated rate is nearly equivalent to
the 58.5% rate that the University receives on most federally funded
grants from the National Institutes of Health, the major source
of external research funds to University faculty. The study also
reported, based on its analysis of ICR for FY 1999, that the actual
ICR rate for external grants was 42%. The study determined that
the reduced ICR led to a significant financial shortfall for the
University. The major contributing factor for the reduced ICR appears
to be due to grants from non government organizations (NGO) which
contribute a much lower ICR than the federal rate of 58.5%. In fact,
more than 50% of the under recovery could be attributed to the modest
ICR provided by NGO grants. The size of the under recovery was also
dependent on whether the ICR was based on a depreciated or non-depreciated
building rate. These rates include the cost for maintaining research
buildings; the depreciated building rate also includes the cost
of deferred maintenance as well as major renovations to research
buildings and laboratories. Approximately 40% of the under recovery
could be accounted for by the difference between the depreciated
and non-depreciated rate. The Committee also noted that the study
did not include an analysis of the efficiency of University services
to determine, for example, if the administrative as well as building
and facilities costs are competitive with industry standards and
that of peer institutions.
Although
concerned with some of the metrics used in the Provost's study,
the Committee felt that the analysis underscores the need for each
externally funded grant to contribute ICR to enable Schools and
the University to recoup the cost for supporting externally funded
research. The Committee, however, does not advise establishment
of a limit on NGO or other grants that compensate the University
with low ICR. Research is core to the mission of the University
and the institution derives numerous benefits from supporting a
vigorous and robust research program; therefore, the Committee recommends
that all research grants be accepted regardless of the ICR rate.
Instead, the Committee recommends that for those external grants,
for which the ICR is below the University "break-even"
rate, consideration should be given to establishing a series of
charges that can be encumbered against the direct cost of these
grants. These charges would enable the Schools and the University
to be reimbursed for administrative and facility costs in relation
to the funded research activity. It may be difficult, however, to
apply a single formula or rate to all projects; several factors
would have to be considered such as the amount of space allocated
for research funded by the project.
Finally,
the Committee determined that the study has tremendous management
potential that could significantly benefit the University, Schools,
and faculty. The study was only able to identify the cost of supporting
research at the University and School levels; however, the individual
schools should be able to utilize the data to determine costs at
the department level and for individual faculty. Therefore, the
Committee recommends that the Provost work with the Deans who in
turn should work with the Department Chairs to use the study for
developing faculty incentives. It should be possible for Deans and
Chairs to use these data to develop performance benchmarks, for
each faculty, that takes into account the cost of supporting their
research program (based on assigned lab space, for example). For
those faculty whose research funding, i.e., ICR, exceeds the university
cost, the faculty should have the choice of either acquiring additional
laboratory space and/or sharing (not for personal gain) in the ICR
surplus. It is the Committee's recommendation that the establishment
of incentives would benefit the entire University community by increasing
both research support and activity.
B. Review
of the Cost in Time and Resources to
Investigators
in Complying with Regulatory Requirements
in Human and Animal Studies
The
Committee was charged with determining the cost in time and resources
to investigators in complying with regulatory requirements in human
and animal studies. It is clear that due to constantly changing
federal regulations the process for approval of animal and human
subject research protocols has become both complex and laborious.
The Committee met with several University officials and found that,
although many problems still exist, significant steps have been
taken to improve and stream-line the process. The Office of Regulatory
Affairs has improved its web sites for both human and animal studies;
each site now contains guidelines and all pertinent forms. Another
recent addition was the ability of investigators to track protocol
(both human and animal) status on BenReports. Perhaps, the most
significant advancement was in the area of human research with the
establishment of the Office of Human Research; this office provides
three services: clinical research development, regulatory compliance
monitoring and education. Finally, further streaming of the process
is anticipated once the new Electronic Research Administration (ERA)
is rolled-out. This system will provide a tool for developing human
subject and laboratory animal protocols along with many other useful
features. The Committee recommended that this topic be reviewed
in the near future once the ERA begins to be phased in.
C. Review
of the Revised University Policy for Postdoctoral Fellows
Nearly
six years go the University established the first comprehensive
policy for Postdoctoral Fellows (PDF). This past year, the Vice
Provost for Research, along with the Provost's Council on Research,
reviewed the policy and proposed several modifications. The major
changes include: (1) the addition of a preamble which essentially
defines a PDF; (2) the extension of the policy to cover all PDFs
including those in the social and behavioral sciences who were not
covered in the present policy; and (3) setting a minimal internal
compensation level distinct from NIH guidelines. The Committee reviewed
the revised policy and recommends that the policy be accepted.
D. Review
of contracts for Sponsored Research Agreements
that
Discriminate Against Selected Foreign Nationals
The
Committee was asked by the Vice Provost for Research to review a
research contract that would potentially violate Section III.F of
the Faculty Handbook which states: "Members of the University
research community shall not be subject to discrimination based
on citizenship with respect to their participation in research activities.
While funding agencies may limit their financial support to particular
groups (such as U.S. citizens), they may not prohibit the participation
of others in University research. Where a research contract deviates
from this policy an exception may be granted by the Vice Provost
for Research after review by the University Council Committee on
Research." The research contract in question involved proprietary
software which came under export controls of the International Traffic
in Arms Regulations (ITAR) and Export Administration Regulations
(EAR). The software was approved for export to all countries except
those which are restricted for anti-terrorism reasons. These restrictions
alone are not in violation of University policy, however, the export
controls also stipulate that foreign persons (non-permanent resident
aliens) from these restricted countries would not be permitted to
have access to this product and hence, not be able to participate
in the research. The Committee concluded that the latter restriction
would indeed violate the University policy on research as stated
in section III.F and did not recommend an exception to the policy.
The Committee recognizes that, as a result of events that have taken
place this past year along with new research opportunities in the
area of bio- and chemical terrorism, this issue will be re-revisited
frequently in the future. The Committee's recommendation was
to maintain the guidelines of The Faculty Handbook
and not waiver from its policy of entering into research contracts
that place explicit restrictions on foreign participation. It was
also recommended that the Committee continue to examine this issue.
--Bruce
J. Shenker, Chair
Research
Committee Members 2001-2002:
Chair: Bruce J. Shenker (Dental Medicine); Faculty:
James Alwine (Medicine), Dan Ben-Amos (SAS), Barbara Bonini (SAS),
Robert Boruch (Education), Francisco Gonzales-Scarano (Medicine),
Katherin A. High (Medicine), Jennifer Pinto-Martin (Nursing), Robert
A. Stine (Wharton) and Andrw B. Rudczynksi (Res. Services).
Graduate/professional students: Danielle
Bujnak (GSAS); Kim Woolf (GSAS) Undergraduate
students: Lincoln Ellis (COL03); Chad Sarver
(COL03) Ex
officio: Neal Nathanson (vice provost, research);
Andrew Rudczynski (executive dir research svcs)
Almanac, Vol. 49, No. 6, October 1, 2002
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