ment of materials and services have been added 

 to grants, and detailed controls are included to 

 insure compliance with administrative regulations 

 on civil rights, fair labor practices, equal opportu- 

 nity, and other areas, all of which have added to 

 the complexity of grant administration. The grant 

 thereby has ceased to be a simple support docu- 

 ment making funds available for research. It has 

 taken on the complexity of a contract, so that in 

 many ways the two are almost indistinguishable. 



The requirements for accountability for the 

 expenditure of Federal funds and compliance with 

 other laws and regulations are the major causes of 

 the increase in paperwork on the part of agencies 

 and recipients of grants and contracts. State and 

 local governments. State universities, and the 

 major independent universities complain about the 

 increasing "intervention"" of the Federal Govern- 

 ment in their research grants. Indeed, the Presi- 

 dent of Harvard University recently said: 



The rising tide of government intervention has 

 begun to provoke serious concern from many 

 colleges and universities. ... In a few short 

 years, universities have been encumbered with 

 a formidable body of regulations, some of 

 which seem unnecessary and most of which 

 cause confusion, administrative expense, and 

 red tape. If this process continues, higher edu- 

 cation will almost certainly lose some of the 

 independence, the flexibility, and the diversity 

 that have helped it to flourish in the past.** 

 Two separate attempts are now being made to 

 deal with this problem. OMB Circulars A- 101, A- 

 102, and A- 110 were developed to simplify and 

 standardize Federal requirements imposed on 

 grantees.9 Federal agencies are now in the pro- 

 cess of implementing these requirements. 'O 



Legislation also is pending which would have 

 the effect of reestablishing the integrity of the tra- 

 ditional grant — the Federal Government would 

 again become a passive supporter or patron of the 

 project." The procurement contract would be 

 used when the Government is the outright pur- 

 chaser of research services. In addition, two new 

 categories would be established, the "assistance 

 contract" and the "cooperative agreement."" 

 Under the assistance contract, the Government 

 would have in certain situations the rights estab- 

 lished in a Federal procurement contract, espe- 

 cially the unilateral right to change or redirect the 

 work if deemed necessary. The cooperative agree- 

 ment would be an arrangement somewhere in 

 between the assistance contract and the grant: the 

 Government would be a partner and active sup- 

 porter of the research, sharing the responsibility 

 with the grantee for certain problems, including 

 involvement in specific decisions and subawards 

 during the performance period. With this new 

 category of award available, the grant could be 

 reestablished or reemphasized as the award that 

 would return to the awardee the right to redirect 

 or change the program when necessary. 



Many believe that clarifying the various research 

 relationships would reduce the confusion in the 

 community. Table 5.1 summarizes these manage- 

 ment alternatives, indicating the roles that the 

 Federal agency and the award recipient would 

 bear. 



••Derek Bok, Harvard University, Ttie President's Report. 

 1974-1975, delivered January 10. 1976. pp. 4 and 22-2.1. 



''Now being incorporated in Federal Management Circular 

 (FMC)73-8. 



'"NSF has implemented these circulars in its new Grant Pol- 

 icy Manual. FedemI Register. July 29. 1977. Part IV. p. 38746. 



"Federal Grant and Cooperative Agreement Act of 1977 

 (S.431 and H.R. 7691). This act was passed hy Congress on Janu- 

 ary 19. 1978. and signed hy the President on February 3. 1978, as 

 Public Law 95-224. 



AGENCY SUPPORT OF BASIC RESEARCH BY FIELD OF SCIENCE 277 



