The letter from Katharina Phillips, President of the Council on Governmental Relations (COGR), addresses the Office of Science and Technology Policy’s (OSTP) call for input on business models in federally funded research. COGR, representing 150 research-intensive universities, emphasizes the unique context of academic research, arguing that traditional "business model" terminology can be misleading when applied to the non-profit, public good-focused nature of universities. The letter underscores that universities' principal contributions—knowledge creation, training, and basic research—are best supported by a stable, mutually beneficial government-university partnership, historically based on Vannevar Bush’s social contract model. COGR cautions against policy changes that overlook the complexity and evolving needs of the research enterprise, particularly in the areas of cost reimbursement and regulatory compliance, where conflicting government approaches have led to significant administrative burdens and cost shifting onto the universities.
The correspondence notes several major concerns, including the difficulties of quantifying returns on basic research investments, the challenges posed by non-uniform implementation and arbitrary revisions of OMB Circulars, and expanding administrative burdens from unfunded mandates. COGR advocates for an equitable, consistent regulatory framework, greater interagency coordination, fair assessment of facilities needs, and recognition of the essential, sometimes unpredictable outcomes of fundamental research, including the value of “negative” findings. The rapid evolution of technology and increased collaboration with industry are recognized as areas necessitating more effective government support, especially in electronic administration and technology transfer. Ultimately, COGR calls for improvements to the federal-university research relationship, particularly in cost and administrative domains, and expresses a readiness to collaborate constructively with OSTP and federal agencies in shaping policies that sustain the vitality of the national research enterprise.
