Universities and funding agencies have good reasons for developing detailed systems of accountability for how grants are spent and how grant funded researchers spend their grant funded time, not to mention effort. Among physical scientists, it is common to blame the bio scientists for the never-ending ethics training and insane paperwork. (I'll just put that out there, and then drop it.)
As regular FSP readers surely know by now, some of these rules and regulations make me crazy.
Example: I found myself promising recently that I would never ever ever use a software site license that I purchased with one grant for any activity not related to that specific grant.
I suppose that in some ways that makes sense, but it would make more sense if what I had purchased was something that could potentially have non-research related uses: a car (in which I might drive my cats to the beach for ice cream cones), a yacht (in which I might have wild parties, when I wasn't being seasick), even a computer (on which I might blog and upload cat wrestling videos to YouTube).
But consider that this software, which has one and only one highly specialized purpose and which cannot be used for anything unrelated to that one highly specialized purpose, can and will only be used in the pursuit of Scientific Knowledge.
Would it really be unethical if I used my grant-purchased site license for a different project? According to the rules and regulations, it would be unethical to do so, but it would be stupid not to. Furthermore, it would be a waste of money to purchase an expensive site license for every single project that could use that software.
The rules should be rewritten to say that purchases such as this one can only be used in the pursuit of Scientific Knowledge. That way, everyone wins. My research group gets to do lots of interesting science things without losing sleep over the ethics, the funding agency facilitates the interesting science through their generous support and sensible policies, we proclaim our results to the world and thank the funding agency in our papers, and everyone is happy.
14 years ago
20 comments:
Wouldn't it be more logical if the cost of the site licence is shared between the grants for the projects that may or may not use that software?
Please do not blame the bioscientists, blame the bioscience administrators. Different things often enough that the biofolks suffer from this madness too.
And yes, having to choose between dishonesty and stupidity seems to be everyday business in science these days. But when it comes to "ethical", I should rather think it is unethical to make up terms and contracts that force scientists to do stuff in a stupid way, than think that those terms and contracts define ethical.
Perhaps I'm not entrenched enough in these things, but it seems ridiculous that one item purchased for one grant would be exclusively used for one grant in a large lab. This was one thing that seemed stupid to me in grad school. Paper purchased on one grant was technically not to be used for another.
Are you kidding me? I'm not getting up each time to add/change paper and the extra cost of upgrading a printer to have different trays does not seem worth it. Then I have to buy different cases of paper?
What happens when the experiment is over and the paper published? You're never supposed to use the software again? Write the cost of the site license into another grant when you have a perfectly good copy there?
Would it really be unethical if I used my grant-purchased site license for a different project? According to the rules and regulations, it would be unethical to do so, but it would be stupid not to.
No, it would not be unethical, nor is it unethical or illegal according to the rules and regulations that govern the use of federal grant funds. As I pointed out yesterday, it is OMB Circular A-21 that provides the interpretation of the statutory law and administrative regulations governing allowable and allocable costs charged to federal science grants.
If your university grants and contracts staff are telling you that a software license of piece of equipment purchased with funds from one grant can never be used for any purpose other than the pursuit of the specific aims of that grant, they are totally wrong, and are grossly misunderstanding Circular A-21.
Just to quote the relevant language again:
If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then, notwithstanding subsection b, the costs may be allocated or transferred to benefited projects on any reasonable basis, consistent with subsections d.(1) and (2).
This means that if you purchased a software license with the purpose at the time of purchase to use that license for pursuing the aims of the grant that the license was charged to, and that you later figure out that the software can be used for some other purpose in your lab related to other projects or activities, that is absolutely fine, so long as the allocation of 100% of the cost of the license to that grant was "reasonable". If you purchased the license to perform necessary analysis of data relating the charged grant, and you then performed all of that analysis, then it was totally reasonable to charge 100% of that license to that grant, regardless of what you do with the software above and beyond that analysis.
Based on yesterday's and today's posts, it sounds like your grants accounting staff are completely ignorant of Circular A-21.
As long as use of program for unintended grant does not impede or prohibit its use for intended grant it should be all good. I would take it as that. Man I'd love to see someone right an equipment grant for a yacht or a jetski.
"Paper purchased on one grant was technically not to be used for another."
Your accountants allow you to buy office supplies. We were told most definitely that paper could *not* be charged to (NSF) grants, and must be paid for out of overhead. If the department ran out of paper or toner, then no one could print anything---private caches of paper or toner could only be purchased out of unrestricted funds, not grant funds.
I used to think it was just the university accountants who thought like this and that funding agencies just wanted science to get done, but I don't think that anymore. I had to promise a funding agency that I would only use the software for this one project.
And I can't share it among grants, in part because other grants don't have a budget line for this item. Also, I would like to use the software to get preliminary data for future proposals (i.e., for grants that do not yet exist).
What is supposed to happen to all the still-functional equipment and software purchased on such a restrictive grant when the grant and project end?
Thank you PhysioProf!
I will be making us of that.
Some local interpretation of federal guidelines are inconsistent and driven by fear of audit, which tends to default to actions being forbidden.
Have you seriously lost sleep over this? Just do it. If they really give you crap about it, take them to court and get the rule changed that way.
I can't imagine they actually have time to ENFORCE rules like this?
I disagree with Janka, I think it *is* the fault of the bioscientists. We wouldn't need these stupid rules if people weren't pressured to be unethical in the first place. Most rules are born after somebody did something egregiously wrong.
But this is a good point about the choice between dishonesty and stupidity. I could write a whole blog post about that. Maybe I will!
And good to know that CPP speaks fluent administrivia-ese. Now I know where to go when I'm confused!
You should ask for new labspace as well. The administrators are fond of telling us that grant overhead is used to pay for the costs associated with your physical space. If resources from one grant cannot be used in anyway for another then this implies you need physical space for every grant. I mean, what if overhead from one grant paid for a lightbulb that provided light only ever shone on discoveries associated to another grant?
unless the software is proprietary and therefore it is a big deal to keep it restricted to prior-approved usages, I don't see what the big deal about using it for other projects is.
I suspect there are people who are very grateful for this rule. It does no harm, because nobody can stop a PI from sharing equipment between different grants. However, it ensures that the PI never has to share equipment with anyone they'd rather not share with. If someone asks to borrow something, you can cheerfully tell them you'd love to let them use it, but sadly you are strictly forbidden to do so. What are they going to do, complain to the administration that you refuse to violate ethical rules? (The worst they could do is to report you for violating them in other cases, but they would look silly doing that, and anyway it would be a pain to get proof.)
I haven't seen this arise in practice, but I bet it's occasionally a real issue. Some people are really abusive of other people's generosity, and it's nice to be able to rule it out in a way that saves face. (Plus grants really aren't intended to pay for moochers.)
Since, as A21 points out, it is strictly forbidden to use federal funds for the purpose of obtaining further federal funds, dear FSP, you are really going to be treading on thin ice there if you use your new software to generate information for new proposals.
Where this really rears its ugly head is for research faculty who absolutely cannot charge 100% of their time to federal grants because they have to have some nominal amount of time to write new grants. SRO administrators break their heads (and ours) about what the percentage of time not charged for must be to escape the auditors
A critical issue that is not usually discussed is the following. The vast majority of faculty at Medical Schools are 100% on soft money (that is, grant money). Remember that 100% effort does not mean 40 hrs/week. 100% effort means ALL the time you devote to science. So, if you work 100 hrs/week, that counts as your 100% effort. Why this ridiculous definition is not being challenged is beyond me. The main point is, however, that most PIs at Medical Schools, technically are not allowed to be writing grants (assuming 100% of their effort is funded by federal grants). What do people think about this?
As far as I've seen there has always been a disconnect between what gets written down on paper and what's actually necessary to get things done.
The previous couple of posts are a good example of this, one I was thinking as I read through all of the comments: as I am on soft money, I can't really budget time to write proposals for future funding (or review papers, or spend time at conferences, or sit down with the HR director to talk about changing my benefits, etc.). And yet all of these things are necessary for continuing my work.
What's to be done? Well, there's what's on paper and there's what's done in real life. Frankly I consider the bureaucracy requiring me to lie to be the unethical side. I am the one being ethical: I am trying to get my work done, and to ensure that I will continue to be able to do so in the future.
Like the DMV, I think there are some people in bureaucratic administrations that need to see all the paperwork done "just so". I recall being a grad student and filling out time sheets for an institute I was spending the summer at. I was getting paid 12 hours/week and I'd forgotten that I'd said I'd work 4 hours for 3 days per week rather than 3 hours for 4 days per week. I filled out my time sheet wrong and had to answer to the payroll guy who was very confused and concerned over my change in reported work time. I knew right away I'd made a mistake, apologized profusely and promised to redo the time sheet. (From then on I send in copies of the first time sheet and filled in the date, so I wouldn't make this mistake again.) But who really cares? 12 hours is 12 hours, and what really matters is that I completed my project in the end, right? Some folks on the administrative side live in a whole different universe. That experience was a good education for the sort of grant nonsense we're talking about here. It's all very silly.
"The main point is, however, that most PIs at Medical Schools, technically are not allowed to be writing grants (assuming 100% of their effort is funded by federal grants). What do people think about this?"
No PI should be allowed to be 100% funded by grants. If the institution is not willing to spend any money on the individual, they should not pretend that the individual is a PI. The rise of huge number of soft-money-only positions has resulted in serious instability in the job market for scientists.
No PI should be allowed to be 100% funded by grants. If the institution is not willing to spend any money on the individual, they should not pretend that the individual is a PI. The rise of huge number of soft-money-only positions has resulted in serious instability in the job market for scientists.
unfortunately this is reality. If PIs aren't being supported by their institutions and yet are not being allowed to be supported on soft money, then they will be out of a job. I am 100% on soft money. I hate that my instution will not make a commitment to me, but nothing I can do about that. The only choice I have is, support myself on soft money, or find a different career. I'm a bit old and have too many financial obligations to be changing careers right now.
It is indeed the reality. My soft money institution has no access to a library and no extra funds to cover time spent on writing proposals or doing paperwork. There is no job security -- if I can't find funding for some large percentage of my salary, I lose my benefits. I only get paid what I can manage to scrounge together, and it makes it hard to start up a group when I have trouble covering my own expenses.
In exchange for this, the overhead is very low compared to a government institute or a university (it's <40%), which could potentially make my proposals more attractive to a review panel since I'm relatively cheap to fund. All I can hope is that in some way this makes it easier for me to be funded (especially as a Co-I on others' proposals, since in comparison to their own cost I look so inexpensive).
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