It was not difficult for the government in the last 20 years partially to turn universities into installations for federally sponsored basic research in space, cancer, agriculture, energy and a thousand other areas. The scientists were delighted to have their work supported and appreciated; the university administrators were delighted to have science expand and, with the additional monies garnered, to have their institutions generally supported and made bigger. Everyone benefited.
The welcome streams of federal money for research, however, opened the channels for a mounting wave of regulation, and there are now at least 59 federal laws and regulations that govern or affect scientific research in universities. Federal regulation is not, prima facie, evil. The obligation of the government to account for money it collectss from its citizens and to require accurate accounting from those to whom the money is extended on behalf of the people is unquestioned. I raise the issue of federal regulation not at all to object to regulation in principle, but to object to it as a set of processes, to how regulation often works.
Because of excessive or unthinking regulation, the relationship between government and universities is seriously damaged. There is powerful resentment on all sides, and distrust. Good will is eroded dangerously, and a strain very old and very deep in our culture -- a radical skepticism bordering on open contempt for our centers of learning with their strange, haughty ways -- surfaces again. In general, federal agencies and universities find each other incomprehensible in structure, obdurate in attitude, intractable in negotiation. This recent and growing schism between government and unversities is not created by science, but it deeply affects the capacity to do science.
It is time for a concrete example. I choose "A-21."
"A-21" refers to that circular from the Office of Management and Budget entitled "Cost Principles for Educational Institutions." In it, the government proposes means to account for its money. It wishes to know if the money is used for the purpose it was given, and if direct and indirect monies are properly accounted for. The OMB says in A-21 that there must be "activity" or "total workload" documentation and that faculty members on federal grants or contracts must report their workload or effort in multiple categories -- research, teaching, service, administration.
Like many other, I object -- on the following grounds: that some individuals in the government must believe the government fully owns a principal investigator and that it has a right to require documentation of that person's "workload" even when that work is unconnected with federally sponsored work; that some individuals in the government must misunderstand completely that it is impossible to segregate teaching from research from administration in doing basic research and impossible to assign precise percentages to these false distinctions; that such requirements to create false categories will inevitably result in reports that are wholly meaningless and many only bury, not reveal, genuine instances or improper use of federal money.
This circular, issued on Sept. 10, 1958, was revised in the summer of 1967 to require detailed segmenting and documentation of faculty effort. The outcry against those regulations led to the formation of a government task force, which recommended that the documentation requirements of A-21 be eliminated. As a result, Circular A-21 was revised and the objectionable requirements on "effort" reporting were dropped.
Did the govrnment forget its own study? Yes. In 1976, the Department of Health, Education and Welfare redrafted A-21 and in general reconstituted those features against which the government taks force had so strongly advised.
Subsequent negotiations on the subject of "workload" documentation between universities, OMB and HEW accountants availed little. A private and independent effort to satisfy the need for accountability and to salvage the decomposing relationship between government and the universities in the area of sponsored basic research resulted in the creation of a National Commission on Research. The NCR asserts the need for proper accountability and sets forth rational, tough, workable grounds for sharing the responsibility as well as the funds. Many urged these recommendations on OMB. Nothing came of the urging. In October 1979, Circular A-21 went into effect.
Then early in fall, OMB approved on an experimental basis a method designed to provide accountability in a much less intrusive fashion for the scientists involved and to yield much more accurate and realistic information for the government agencies. I hope this method is designed to work. I hope that with regard to documentation of "total workload" the OMB does not remain forever enthralled by its own regulatory rhetoric. We will see. In the meantime, never have I seen the lash of federal regulation applied to a crucial area of the nation's intellectual life with such seeming indifference to financial and human consequences. In its issue of Oct. 3, Science magazine estimated that at Stanford University alone, these new regulations would require an increase from 3,000 to 80,000 reports annually and $250,000 to $300,000 to put in place the new reporting system.
What is needed? Aside from the issues involved in A-21 or any other specific set of regulations, we continue to need leadership capable of transcending special interests and seeing -- whole -- the public interest. Whether in the areas of basic research of of financing higher education, whether around regulations concerning safety or athletics or informed consent or waste disposal, there must be no lessening of the moral imperatives, or of necessary accountability.
But there must be at all levels of government, and the university, some renewed mutual respect, some common conviction that it is in the nation's interest that government and centers of learning collaborate and that the purpose of collaboration is the betterment of the nation's life. There must be some disposition to identify the larger issues and find reasonable solutions within a general perspective that recognizes institutional differences and common goals. Too much is at stake for all of us.