A consultation on reforming parts ofthe Dual Support system
Sur 3.1
The proposed alternative model of adding the increasedfunding to increase the current overhead has not only the advantage ofsimplicity, but also identifies the true cost of research despite what theconsultation document says. Paragraph34 HEIs would use the project costing methodology to calculate theFEC. The disadvantage is that it doesnot address the issue of charitable funding which does not carry anoverhead. However, there would be moreQR funding available because of the increased overhead in Research Councilgrants. However, the QR must besufficient.
A major problem with the whole consultation documentis absence of any significant modelling of the effects of the various optionson research and universities. Thus theFEC methodology has not been validated yet and the funding available to eachResearch Council and charity over the next few years is unclear. Until these data are clearer and somemodelling of the effects of the different dual support methods is produced, itis impossible to make a considered judgement on these issues. For instance, another model would be to usethe methodology proposed in the document, but, in addition to convert the QR tofunding for Research Councils and use this to increase the total overhead. The disadvantages of this are all of these,which apply to abolition of dual support as well as not addressing the issuesof charitable funding. Accordingly thismodel is not supported.
Sur 3.2
It is debatable whether this is relevant. All universities in the UK are in a fairlysimilar position with regard to under-investment/inefficiency. It may be the case that some have beenparticularly lax and could therefore benefit from a larger FEC per researchgrant, but it is arguable that these institutions will be uncompetitive insecuring research funding. Furthermore,Research Councils when looking at the FEC of applications will no doubtconsider this issue when they look at value for money.
Sur 3.3
In principle, we support the concept of full economiccost (FEC) as a means of reversing the under-funding of research. The one reservation is the allocation of aPrincipal Investigators (PI) time within the FEC as this may lead to fundingof part of the PIs salary from external funding with all the attendant uncertainties. We also agree that QR should provide salarycosts of permanent academic research staff, a contribution to costs of trainingof new researchers, should fund some blue-skies research and should buildresearch capability.
The proposal that Research Councils (RCs) pay a fixedproportion of FEC is acceptable, as long as the proportion is sufficient. The definition of sufficient iscrucial. There is also a directrelationship to sufficient QR funding being available to make up the differencein the FEC. The major concern is thatthere will not be sufficient funding in the system (Research Council fundingand QR). This is particularly vital formedical schools, which have a large amount of charitable funding.
Similarly a major concern is that universities willpre-commit all QR when making grant applications to demonstrate theaffordability of the FEC of a grant and to ensure that funding isobtained. One result may be thatuniversities lose all flexibility with QR.In effect, the dual support system will have been converted to agrant-related overhead, the complete antithesis of the philosophy of dualsupport. This will particularly have anadverse effect on Arts subjects, which are especially dependent on QR.
Alternatively, if universities refuse to bid forfunding to preserve the flexibility of QR and to prevent grants earning QR,then research will not be done simply because researchers do not apply. This problem will be particularly acute atthe most research-successful institutions.At a time when the Funding Councils have espoused researchconcentration, the danger is that insufficient funding of FEC for theseuniversities will act in the opposite direction. Thus top-quality research will not be carried out.
Yet another outcome may be the universities willdeliberately under-estimate the FEC, resulting in perpetuation of the intrinsicproblem.
Sur 3.4
The attraction of a single percentage of FEC isobvious simplicity. If the true FECis calculated, the impact of costing varying amounts of PIs time on different disciplinesis unfounded, from the universities viewpoint, as the total cost iscovered. This presumably will result ingrants to the Arts and Humanities being larger than at present, but this wouldbe a good thing, as long as the funding available to AHRC is increasedcommensurately. The concern that thiswould decrease funding for the Sciences (if the total funding is not increased)is probably of less importance, given the enormous disparity of total fundingat present. Over time, funding betweenthe RCs would be re-balanced in response to the demonstrated demand of highquality research.
To reduce potential turbulence, this model should notbe put into effect until sufficient time has elapsed to allow a full grantapplication cycle. Thus with regard toallocation of the extra 120m, this should be allocated to RCs pro rata totheir current total funding as an interim solution.
Sur 3.5, 3.6 see Sur 3.4
Sur 3.7
Research Councils should fund the best applicationswithin their defined brief and not try to manage the market. The increased administration and need formatching funding to demonstrate that the university can cover the FEC of agrant will act as major discipline to eliminate frivolous applications.
Sur 3.8
It is likely that as the FECs are identified, unlessthe overall funding available to Research Councils charities increasesproportionately, there will be that many fewer successful grantapplications. While it is in principleacceptable that only the highest quality research should be funded, the realityis that, even at present, substantial amounts of the highest-rated research arenot funded due to financial constraints.This problem will inevitably get worse if the overall increase in funding(Research Councils and charities and QR) does not reflect the increasein cost/grant that FEC will produce.This would be a major own-goal for the UK at a time when theinternational competition is ever increasing.
The consultation document makes very little explicitreference to research funded by the NHS and the charities and to the potentialimpact of its proposals on these organisations. This is particularly important as the funding of research for,and by the NHS, is in a state of both considerable flux and uncertainty aboutits future structure. It is vital thatproper consultation with NHS R&D is undertaken as the medical schools havea complex, intimate and challenging relationship with NHS R&D. Similarly, the medical schools have large(greater than 50%) funding from charities, who do not pay any overheads. It is therefore extremely important that QRis sufficient to provide the FEC of charity research and also follows suchresearch. Thus, proper consultationwith the charity sector is vital to the medical schools, as a failure/refusalby charities to pay an appropriate proportion of the FEC would effectivelyremove this crucial source of funding from the medical schools.
Sur 3.9
Given the enormous complexity for both researchers andinstitutions and the cultural shift required, there is no chance thatmid-research HEIs will find the proposed benefits sufficient to invest thelarge resources which would be required for a September 2004 start date.
Sur 3.10
These should be neither shadow-running nor mixedeconomy. Either of these approacheswould result in enormous unnecessary administration. The changes should be implemented at a single time point. If there is not sufficient time to implementthis by September 2004, then the date should be deferred.
Sur 3.11
Research studentships should have indirect costsupport and should be included in this system.These posts are the lifeblood of academia and it is vital to fosterthem. Currently the funding almostcertainly does not cover the costs (although accurate data are not widelyavailable). Given their importance,this should be addressed by providing proper indirect costs.
Sur 4.1, 4.2
The guidance, while useful, does not fully recognisethe great complexities that will arise out of this major shift in themethodology of research funding. Thereis an enormous range of fundors (RCs, government departments, etc.) andapplicants addressing many different research interests. It would be better to pilot the TRACmethodology and its use in grant applications in the pilot institutions (orothers) before full implementation.Otherwise major destabilisation could occur, rather like the shift todual support in the early 1990s.