Simplification of EC rules

Recently, I was asked to talk to the European Union Ministers of Science on the topic of “Simplification”. That would be a great title for an Irish Leaving Certificate English essay – even if it could give rise to a confusion of choices. For my talk, things were happily more constrained; I had to speak from the perspective of an academic/researcher about the administrative burden associated with awards in the Framework Programme (FP). There was also a speaker from a large company representing industry views. As SMEs have real problems with FP regulations, it was good that both of us addressed their needs and concerns.

The meeting itself was in a large building in Brussels called, inelegantly, ‘Tours and Taxis’! The 27 Ministers (in Ireland’s case, Conor Lenihan, TD, Minister for Science, Technology & Innovation) plus “our” Commissioner and a representative from the European Parliament were all present in a very large room with a square-shaped layout, multiple screens and translation in six languages. As is the case in such events, there had previously been a series of background documents prepared by the European Commission (EC), and the Commissioner had put it on record that she wanted things to be made more simple in future FPs. The need to have simplification is best illustrated by the fact that there is a growth industry for consultants to prepare (and often lobby for) research applications!

For me, the biggest problem with the current rules is how they are applied. Essentially, the attitude seems to be that the research community cannot be trusted. As a result, time-sheets are required for those employed on an EC award. For an artist, I think it would be understood that timesheets are not appropriate. The inspiration that is needed comes from many sources and at different times. And when the idea is clear there is no point in just working from 9 to 5. The same is true for researchers. They constantly read scientific papers, think non-stop about the latest results and conjure up the next experimental approach whenever the creative juices flow. In Germany, I walked our dog every morning and that was a great time for reflection and consideration about where the latest data pointed to. This behaviour does not match the need to show that 165 hours were clocked in at work on a project. So timesheets are filled to match the required hours that had been included in the proposal. They are usually fictional – but not fraudulent. The real times are, in my experience, longer and less regular and just do not fit the administrative boxes that have to be ticked for the EC.

The second problem is the fact that the research is viewed as a straight-forward contract – you say what you will do, define the timed steps towards doing it (milestones), list the outcomes that are to be delivered and report on this on a regular basis – all very appropriate for a predictable applied project, but not for one at the frontiers of research. One specific problem is that the time between the application and the formal start-date of a project can be up to two years. If the proposed research is of any importance, then much will have changed between the application that was prepared and the details at the end of the four-year project. Nonetheless, the milestones are the ones that have to be monitored by the Commission. The end-point should not change as that was the promise that got funded, but the way to achieve the goal almost of necessity will be altered. As a colleague once remarked, ‘Bees make honey, but you should not think that they will all fly in a predictable direction when achieving that deliverable’.

Then, there is an obsession by the system with ensuring that the money is spent in an absolutely correct manner. As this, ultimately is taxpayers’ money, this is as it should be. But there are different ways to ensure that it happens. The EC has special auditing rules (not nationally-accepted ones) that have to be adhered to (although the Commission is discussing a change on this rule). The cost and complexity of this is a real and unnecessary burden, especially for small companies. The need for such rigour with Higher Education Institutes is more difficult to fathom. The universities in Europe are very predominantly part of the national education systems. They also need to return to the FP many times annually with new proposals from their staff. As a captive customer, their motivation to do things right is very high. They are reliable clients. It follows that the risk of fraudulent activities are very low. Interestingly, the Commission is discussing a rule change to make provision (tolerance) for an “error” rate of 3-5%.and that should cover the occasional errors that are inevitable when dealing with billions of Euro in multiple transactions.

When risks associated with the FP are analysed, I am sure that the residual risk for financial fraud by a University is extremely low. A random intense audit would ensure that all in the system adhere to the current level of good behaviour. But again, trust and a real understanding of the research system is needed for this to change. In my opinion, the real risk is not financial, but rather a failure to achieve the maximum possible from the funds that are available. Performance (other than reaching out of date predefined milestones) is harder to judge and needs more people with the skills to see both the quality of what is achieved and the potential that has been ignored. And those individuals are not readily available in the Commission services where the emphasis is on selection of projects and ensuring that the accounts are in perfect order, rather than monitoring post-award performance.

The latter point is also relevant to the discussion within the Commission that payment would be “results-based” rather than on the content of the proposal. Great skill (the ones I suggest are lacking at present) would be needed to decide if the final results match expectations or even to define “best effort” and I do not think that SMEs or Universities could launch into an expensive research programme if they did not have assurance that the money would be paid by the Commission at the end of the programme. A predictable outcome would be that much safer (and hence, of lower potential) would become the norm as in this way the risk of not delivering on the proposal would be greatly reduced.

When I finished my presentation (and I list my recommendations at the end of this piece) the Industry representative, Gee Rittenhouse from Alcatel-Lucent-Bell Labs, spoke. As there had been no communication between us prior to the meeting, it was a little nerve-wracking wondering if he would have a completely different take on the question than I had done. Happily, he agreed with all my points and, in particular, an emphasis I put on the fact that Research is exploratory and is not an industrial process. Hence, the exact route that research must take is less predictable. From the industry side, he pointed to the costs of adhering to the admin rules and agreed with me that this was excluding smaller businesses. He stressed that when Innovation was needed (rather than earlier-stage research) the absolute requirement was speed…and again the FP is not champion in this. Finally, he pointed to the difference in ambition for good projects that his company is involved in the FP and in the business world. In an FP consortium, the aim was to achieve a two-fold increase in energy efficiency. In an open innovation network, with a longer timeframe, and without the challenge of convincing a classical peer review system, the aim is to get a 1,000-fold improvement.

When finished, the many Ministers made statements. But most of these were read from briefs that had been written before they got on the flight to Brussels and it was difficult to gauge if they had taken on board the content of the day. But that is how it works. Hopefully, somebody agreed with some of the points that were made, or found in them confirmation of their own ideas. If so, future documents will have that flavour and with time (hopefully not too long) the clichéd criticism of the FP that is more interested in administrative processes than in action will be outmoded.

The recommendations I made were;
• Stop requesting Timesheets
• Set in place systems that drastically reduce the time needed to get projects started
• Trust the Investigators to adjust programmes as they deem necessary
• Increase scientific staff to allow projects to be closely monitored during and at the end of the project
• Provide a bonus for excellent performance but do not introduce more uncertainty through results based payments
• Have Controls that are Proportional to the risks in this community

• Regulatory processes designed for PRODUCTION are not appropriate for EXPLORATION and research has to be exploratory

One thought on “Simplification of EC rules

  1. Seamus Martin

    Dear Frank,

    As I read the above I have the distinct sense of deja vu. The majority of scientists agree with everything that is written above and such comments have been made time and again over the past number of years. So, why does it seem that nobody is listening to these very sensible and reasonable arguments?

    For many, the administration and red tape associated with doing research is now becoming such a turn off that they would rather apply for fewer grants and run smaller labs than they would have otherwise done in a more supportive research environment. The primary objective now appears to be to avoid transgressing any of the numerous rules rather than concentrate on the actual research. A sad state of affairs.

    If this climate of creeping micromanagement and endless administration does not change the EU funding mechanisms will continue to produce little in the way of quality science. Maybe in the future, there will be no need for any actual scientific content in an EU grant proposal, just a 10 page description of how any funds awarded will be managed and accounted for. We are nearly there already.

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