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Misconduct in Biomedical Research Ulrike Beisiegel (PhD) University Medical Center of Hamburg-Eppendorf Speaker of the Ombudsman of the DFG DFG Memorandum Proposals for Safeguarding Good Scientific Practice (1998) Recommendation of the Commission on Professional Self Regulation in Science in Germany ‘The conduct of Science rests on basic principles valid in all countries and in all scientific disciplines. The first among these is honesty towards oneself and towards others. Honesty is both an ethical principle and the basis for the rules, the details of which differ by discipline, of professional conduct in science, i.e. of good scientific practice. Conveying the principle of honesty to students and to young scientists and scholars is one of the principle missions of Universities. Safeguarding its observance in practice is one of the principle tasks of the self- government of science‘. http://www.dfg.de Recommendation 16 ‘The DFG should appoint an independent authority in form of an Ombudsman and equip it with the necessary resources for exercising its functions. Its mandate should be to advise and assist scientists and scholars in questions of good scientific practice and its impairment through scientific dishonesty, and to give an annual public report on its work’. Recommendation 8 ‘Universities and research institutes shall establish procedures for dealing with allegations of scientific misconduct’. Recommendations 9 and 10 include other institutions, like MPG, and learned societies. Six Years Ombudsman of the DFG in Germany (1999-2005) Report of the first team employed by the DFG (Profs Trute, Geiler, Grossmann) 162 cases: 51 from the medical field 37 from natural sciences + economy, social sciences and engineering ….additional 29 calls not considered ……highest percentage from biomedical research What kind of cases have been observed? (total number of cases 162) 1. Falsification and scientific misconduct (35) Recommendation 1 2. Authorship questions (30) Recommendation 11 3. Incomplete references and plagiarism (18) Recommendation 12 4. Others…….(79) Fundamentals of Scientific work: Recommendation 1 • observing professional standards (quality control) • documenting results (10 years storage) • consistently questioning one‘s own findings • practicing strict honesty with regard to the contributions of partners, competitors and predecessors Research is .....any activity which in content and form constitutes a serious, systematic effort to find out the truth…. Federal Constitutional Court in 1973 – BVerfGE 35,79 Situation in Bioscience Falsification Dishonesty .. committee for handling allegations of scientific misconduct…. Ombudsman What is special in Biomedical Research? • lack of reproducibility in living systems • extremely fast methodological development • high commercial interest • public interest and pressure • ethical problems Lack of reproducibility: • Cases are unique, no verification possible • Patients samples cannot easily be replaced • Animal colonies are not identical • Tissue culture is dependent on ‘environment’ Example 1: Clinical study Urgent need to include ten additional patients in two weeks…… Finally 3 more……, but all three pre-operative blood samples are lost while centrifugation….. What to do? → be honest and risk career (interest of project leader!) → use earlier values and please the ‘boss’ - dishonesty Structural Problems in the Medical System • highly hierarchical system • little scientific education in medical school • lack of time for research • lack of quality control → dishonesty helps to get along with these disadvantages Problems due to Hierarchy • leadership problems – group size • pressure instead of promotion • lack of communication (unidirectional) • mainly monetary interest • authorship problems Authorship Recommendation 11 and 12 ‘Authors should be those, and only those, who have made significant contributions to the conception of studies or experiments, to the generation, analysis and interpretation of the data, and to preparing the manuscript…’ ‘..the responsibility for obtaining the fund, contribution of material, training of co-authors, involvement in collection of data and directing the institution …. are not themselves regarded sufficient to justify authorship. Example 2: Order of Authorship Graduate student performs all experiments in a project from a head doctor in the clinic of Prof. X…. Exciting results should be published! What is the order of authors? → 1. student; 2. head doctor → 1. head doctor; 2. student; 3. Prof. X Honorary Author Example 3: ‘Overseen’ Authors Graduate student or postdoc X performs all experiments in a project – finishes his thesis/project – leaves the lab for his further career (even though the project leader wants to keep him)…….. before leaving X prepares a first draft of a manuscript…… not yet perfectly written….. What should the project leader do? → rewrite the manuscript and publish alone since X left → correct the manuscript and publish it with X Publication Policies in Biomedical Science • number of publication counted instead of quality assessment Recommendation 6 → fragments published instead of whole story → too many journals of low quality → reviewers not enough time • online publication – how can we keep quality ? Situation in Bioscience Falsification Dishonesty Ombudsman Future Strategies for the Ombudsman together with Prof. Loewer and Prof. Hunklinger • increase the awareness for good scientific practice • increase the acceptance of the Ombudsman • encourage young scientist to request honesty • improve system of mentorship at universities • implement adequate organizational structures to improve communication and reduce hierarchy National Science Foundation Office of Inspector General Misconduct vs. Fraud Christine C. Boesz, Dr.P.H. Inspector General U.S. v. Dr. S. ● Offense: ● Dr. S, a professor at a U.S. university, submitted a Small Business Innovation Research (SBIR) proposal to NSF in the name of his wife, as president of a small business ● NSF awarded a Phase I grant for $99,300 ● No research was done; they simply wrote checks to themselves for salary, rent, and materials — and to their son’s college for tuition U.S. v. Dr. S ● Offense, cont’d: ● Dr. S. submitted a Final Report to NSF for the Phase I grant--text was copied from his former student’s Master’s thesis ● Dr. S submitted a Phase II proposal to NSF in his wife’s name — NSF awarded a Phase II grant for $399,982, made first payment of $99,974 ● They paid most of the money to themselves, but did pay for some research done by a subcontractor, and began setting up a lab U.S. v. Dr. S ● Investigation: ● The university found out — notified NSF — began process to fire Dr. S — he eventually resigned ● OIG interviewed the former student whose Master’s thesis was copied into Phase I Final Report ● When Dr. S requested the next grant payment from NSF, he learned about OIG interest — he called OIG and offered for both he and his wife to come and talk to us — both made significant admissions U.S. v. Dr. S. ● Investigation / Prosecution: ● OIG recommended that NSF suspend the grant (which NSF did), issued subpoenas, and referred the case to the Justice Department Criminal Division, which accepted it ● At a meeting at DOJ with their attorneys, all tentatively agreed: ● Dr. S. was primarily responsible and would plead guilty to a criminal count ● They would repay all grant funds ● No action would be taken against his wife U.S. v. Dr. S. ● Restitution: ● To demonstrate good faith, they offered to immediately pay back more than they stole ● But NSF cannot supplement its appropriations, so could only receive reimbursement of $199,274 ● However, NSF can receive unrestricted gifts, so they donated additional $27,500 to NSF ● Total received by NSF: $226,774 U.S. v. Dr. S. ● Sentencing: ● Under the Federal Sentencing Guidelines, the dollar amount charged is important — in this case, charging less than $120,000 would give Dr. S. a chance to avoid jail ● Dr. S. was charged with the $99,300 fraudulently received under Phase I, and not the Phase II funds ● Judge imposed sentence: 5 years probation + $15,000 fine U.S. v. Dr. S. ● Administrative settlement terms: ● Grant terminated, company dissolved ● Dr. S debarred government-wide for 3 years ● Dr. S. can get a new faculty position, and only has to disclose debarment to new employer if he is going to be involved with federal funds Netherlands Organisation for Scientific Research 1 Overhead Costs in Research Grants in the Netherlands Gertjan Boshuizen, NWO International Workshop on Accountability in Science Funding June 1, 2005 Netherlands Organisation for Scientific Research 2 Situation in the Netherlands – Funding NWO – Matching: the price of succes – Other remarks – Overhead = indirect costs Netherlands Organisation for Scientific Research 3 Public Research funding in The Netherlands Researcher Institutes Departments Universities Research Councils & other Institutes NWO Government Netherlands Organisation for Scientific Research 4 Funding NWO (till 1999) – NWO paid: – Researchers (on pay-roll NWO) – Other direct costs (material, consumables) – Arrangement for all the other costs (infrastructure, etc) – Part of the direct Government funding – M€ 40 – Share per university fixed from 1993 Netherlands Organisation for Scientific Research 5 Funding NWO after 1999 – Salary per categorie (Phd, postdoc) – Fixed percentage for social security, pension – Fixed percentage for certain overhead costs – Used to be costs for NWO till 1999 – Amount for risk of unemployment – Direct material costs – Still: arrangement M€ 40 (but nobody knows anymore) – Pressure on direct material costs (i.e. laptop) Netherlands Organisation for Scientific Research 6 Developments in the Netherlands – Other funding parties use NWO (industry) – Growth in funding NWO & sources funding – Growth in funding other organisations (EU) – Government funding: more directed by performance Netherlands Organisation for Scientific Research 7 Matching: the price of succes – Report Advisory Council for Science and Technology Policy (AWT) – Restrictions on scope for expenditure – Study by E&Y – Practice of matching at five universities Netherlands Organisation for Scientific Research 8 Full costs, overhead & matching Matching Grant Indirect Costs Material costs Personel costs Netherlands Organisation for Scientific Research 9 Results E&Y (division full costs) 43 38 19 Personel Material Indirect Netherlands Organisation for Scientific Research 10 Indirect costs – Traceable overhead: – Support by other researchers (ca 10 % personel costs) – Support staff: laboratory, technicians – Housing – Equipment etc – Computer – Common Overhead: finance dept, hrm dept – Poor cost accounting systems Netherlands Organisation for Scientific Research 11 Results (% of costs funded) 0 10 20 30 40 50 60 70 80 90 100 per mat ind tot nwo contract total Netherlands Organisation for Scientific Research 12 Results (% of full costs funded per university) 0 10 20 30 40 50 60 70 80 un1 un2 un3 un4 un5 nwo contract total Netherlands Organisation for Scientific Research 13 Results leads to next figure (2002, M€) Government funding 2.550 For research 1.500 NWO & contract-research 985 54 % Matching 826 826 46 % Full costs 1.811 100 % Strategic research 674 Netherlands Organisation for Scientific Research 14 Conclusion study E&Y – Subsidies mostly limited to direct costs personnel & material – Using the existing research infrastructure – More than half of total budget government funding tied up Netherlands Organisation for Scientific Research 15 Conclusion AWT – Serious problem with matching – Undermining strength and quality research – Strategic choices are difficult: – Time horizon – Uncertainty – Broad variety Netherlands Organisation for Scientific Research 16 Position NWO – Funding Government: – Infrastructure – Common overhead – NWO: funds direct costs of top quality research – Open competition – Talent – Themes (only here influence on content research) – Contract research should be up to 100 % of full cost Netherlands Organisation for Scientific Research 17 Why bother about overhead costs? – Do we bother about the overhead costs of KPMG, E&Y or PWC? – Overhead costs of research institutions: – Are based on (different) cost accounting systems – Different allocation methods – Contain inefficiency – Costs of accounting and checking Netherlands Organisation for Scientific Research 18 Conclusion – Why overhead in grants: – Depends on direct government funding – In the end: no research – How much: – Depends on direct government funding – No funding of ineffeciency and overcapacity – Somewhere between 0 % and 50 % – How checked: – Not relevant – Part of audit by CPA Dr Ian Carter Director of Research University of Liverpool Implications of Full Economic Costing Context z Sector over-trading z Seven years of reviews, consultations, policy changes, SR allocations … Treasury-led z Government requirements of HEIs and of some funders – Expects institutions to take responsibility for their own financial sustainability, particularly in respect of research infrastructure – Cost and price all research and related activity based on FEC – Show there are sufficient funds to meet the full costs of all research, year on year Implication ⇒ In US terms, effectively moving from undocumented cost sharing to documented cost sharing Broad Issues z Issues are pervasive, managerial, and cultural z TRAC timetable is to 2009, not just 2005 z Affects T as well as R z Issues for the individual researcher, the HoD, the Dean, the admin z What to support … strategic choices … effects on careers z Management and allocation of core funds Areas of Change z Implementing the technical changes z Addressing managerial and cultural change z Pricing and market interactions z Accountability issues Technical Changes z National TRAC Manual – Minimum requirements over a time period – Plus “best practice” z Changes to accounting and management systems z Understanding staff time use z Application, award and operational processes z Variation between funders Managerial and Cultural Change z Planning and Resourcing – Changes to resource allocation and to budgeting / planning cycle – Role of relevant committees and individuals z People and HR – Staff management and engagement – Integration of personal objectives with departmental planning z Management Structures and Responsibilities – Relative responsibilities between HoD, Dean, PVC and SMT – Levels of devolved responsibility Pricing and Market Issues z How are prices affected, now we know costs? z Regulated markets: – Research Councils required to change their funding mechanism – Charities “not affected” … but potentially greater charging of direct costs – European Commission: FP7 and ERC on an FEC basis? z Unregulated markets: – Price negotiation: need to offer value to customer Accountability z Future QA / Dipstick processes are not yet clear z Funders’ recognition of real costs – Schemes that require cost sharing – Audit requirements that aren’t an eligible cost z Differences between funders – Potentially significant burdens imposed by bodies providing small proportion of funds Summary of Issues z Pervasive nature z Technical, managerial and cultural change z Forces consideration of “difficult” issues z Opportunity for clarity … Dr Ian Carter Director of Research University of Liverpool i.carter@liv.ac.uk Implications of Full Economic Costing 08/02/2005 IMPROVING ACCOUNTABILITY OVER NSF GRANTS: A CASE STUDY International Workshop on Accountability in Science Funding June 2, 2005 Grant Accountability Framework 08/02/2005 Objective To provide: An overview of NSF’s processes for overseeing and monitoring its research and education awards; An understanding of the NSF Office of Inspector General’s role in evaluating these processes; and How NSF and OIG, together, are working to improve the agency’s accountability for research funds. 08/02/2005 Background NSF: Receives an annual budget of about $5.5 billion (US) to promote and advance the progress of science and engineering; and Makes about 10,000 awards each year to over 2,500 institutions. 08/02/2005 Background NSF’s ability to carry out its mission depends on how well it manages its awards and builds accountability into its grant management processes. 08/02/2005 Elements of Grant Accountability NSF’s grant process has three basic phases: Preaward; Active Award; and Closeout. 08/02/2005 Elements of Grant Accountability Two principal forms of accountability affect each of these grant phases: Scientific—focuses on scientific or programmatic performance; and Financial/administrative—focuses on compliance with accounting and administrative requirements. 08/02/2005 Did NSF pay only for allowable and reasonable costs of its awards? Does NSF have adequatelytrained staff and sufficientresources to award andmanage its grants?Is NSF making awards to financially capable institutions? Are NSF awardees properly accounting for, charging, and reporting costs on NSF awards? Preaward Is NSF making awards for the most meritorious grant proposals? ScientificFinancialCloseout Is NSF obtaining intended scientific results? Elements of AccountabilitySta ff a nd Re sou rce s Post Award Phase Grant Accountability Framework Grant Life Cycle: Active Award Are NSF awardees making adequate scientific progress? 08/02/2005 Grant Accountability Is requiring significant effort by NSF management and the OIG to: Address these scientific and financial accountability questions; and Ensure NSF has adequate controls in place to continuously manage its awards throughout their life. 08/02/2005 Scientific Accountability in Preaward Phase NSF relies on selected researchers to evaluate the scientific merit of the research proposals it receives. NSF maintains a database of about 300,000 potential reviewers. NSF received almost 44,000 proposals in FY 2004, and selected more than 96% of its research awards through the merit review process. 08/02/2005 Scientific Accountability in Preaward Phase NSF uses two merit review criteria to evaluate its proposals: Intellectual merit; and Broader impacts. 08/02/2005 Scientific Accountability in Preaward Phase External reviewers are essential inputs that inform the judgment of the Program Officer. Program Officers recommend to award or not to NSF senior management, considering additional issues. Each Program Officer’s goal is a well- balanced portfolio of research awards within a given program. 08/02/2005 Scientific Accountability in Preaward Phase NSF relies on its Committees of Visitors (external advisors) to help assess effectiveness of the merit review process. Committees of Visitors assess NSF's technical and managerial stewardship of a specific program or cluster of programs approximately once every three years. This assessment includes commenting on: The quality, effectiveness, and implementation of merit review process; and The program’s award accomplishments and results, as selected by NSF Program Officers. 08/02/2005 Scientific Accountability in Preaward Phase OIG assesses the effectiveness of NSF’s merit review process as low to medium risk. Audits have found few issues with the process. At the request of Congress, the National Science Board has initiated a “structured evaluation of NSF’s system of merit review.” 08/02/2005 Financial Accountability in Preaward Phase NSF policy requires grant recipients to have financial management systems that provide accurate and complete accounting of NSF award funds and claim only allowable costs. To ensure financial capability, NSF policy requires preaward reviews of all new awardee accounting systems, proposed budgets and indirect cost proposals. 08/02/2005 Financial Accountability in Preaward Phase OIG assesses effectiveness of NSF’s financial preaward reviews as medium to high risk. OIG has not reviewed NSF’s preaward review process, but: OIG preaward and post award audits have found grant management and accounting problems at awardee institutions; and OIG has concerns about the sufficiency of NSF staff to perform preaward reviews. 08/02/2005 Scientific Accountability in Active Award Phase NSF policies generally task Program Officers with monitoring the scientific, engineering, and educational aspects of their awards. However, policies provide no specific guidance as to how Program Officers should accomplish this oversight. NSF’s Grant Policy Manual specifically charges the grantee institution with responsibility for monitoring a project. 08/02/2005 Scientific Accountability in Active Award Phase While not specifically described as monitoring, a few NSF policies outline requirements that involve monitoring. PO approval required for situations such as changes in project scope or change in PIs. Annual progress reports required for longer-term awards, generally lasting 24 months or more. For continuing grants, NSF provides funding incrementally, with the funding dependent upon NSF’s receipt of progress reports. 08/02/2005 Scientific Accountability in Active Award Phase OIG assesses the effectiveness of NSF’s monitoring of scientific progress as medium to high risk. NSF has few specific requirements and procedures for Program Officers to monitor scientific progress, NSF indicates heavy workload and insufficient staffing and travel funds as limiting project oversight. OIG audit identified issues with untimely and missing progress reports. 08/02/2005 Financial Accountability in Active Award Phase NSF policy holds the awardee responsible for the day to day accounting of costs charged to the award. Quarterly, the awardee must report and certify its award expenditures, and NSF reconciles these reported expenditures to its cash balance records. 08/02/2005 Financial Accountability in Active Award Phase OIG assesses effectiveness of NSF review of financial reports as medium to high risk. The audit of NSF’s financial statements identified the need to better monitor financial reports: Is the information provided complete? Does the cash flow reconcile with reported expenditures? OIG post award audits continue to find unallowable and unsupportable costs. 08/02/2005 Scientific Accountability in Closeout Phase NSF relies on advisory committees to assess and report on the outputs and outcomes of its investments. Committees of Visitors assess performance of approximately 1/3 of NSF’s programs annually. An Advisory Committee for Performance Assessment annually assesses NSF performance as a whole, based primarily on these Committees of Visitors’ assessments. 08/02/2005 Scientific Accountability in Closeout Phase OIG assesses the effectiveness of NSF’s assessment and reporting on outputs and outcomes of its investments as medium to high risk. OIG audit found Committees of Visitors were useful to NSF in managing its programs, but NSF needed to improve its disclosures for performance reporting. OIG audit of Math and Science Partnerships identified issues with how each project planned to evaluate its research activities. 08/02/2005 Financial Accountability in Closeout Phase NSF relies on a risk-based award monitoring program and financial audits of awardees to ensure the propriety of awardee expenditures under its grants. 08/02/2005 Financial Accountability in Closeout Phase NSF initiated, in 2003, a program to assess risk of its awardees and to perform on-site reviews of financial operations of high-risk awardees. NSF awardees also must be audited by an external public accounting firm if they spend $500,000 (US) or more in federal funds, including NSF funds (known as Single Audits). OIG also conducts audits of 20 to 30 NSF awardees annually. 08/02/2005 Financial Accountability in Closeout Phase OIG assesses effectiveness of NSF’s risk- monitoring program as medium to high risk. Annual audits of NSF’s financial statements have: Identified post award monitoring as a continuing issue; and Recommended improvements in NSF’s risk assessment model, its on-site visit procedures, and the availability of adequate staff and resources. Outside consultants recommended improvements in NSF’s monitoring activities. 08/02/2005 Financial Accountability in Closeout Phase OIG has concerns with overall quality of awardees’ single audits and the extent that NSF awards are tested. OIG audits of NSF awardees continue to identify financial control weaknesses and unallowable costs. NSF will need to implement, in 2006, a plan to statistically sample its annual awardee expenditures to identify unallowable costs under the Improper Payments Act of 2002. NSF also plans to contract out some post award monitoring activities. 08/02/2005 Scientific and Financial Accountability Throughout Award Life NSF manages over 35,000 active awards and processes over 40,000 proposals annually. NSF’s budget has grown from $3.9 billion to $5.5 billion over the past 5 years, but its total staffing levels have remained relatively stable at about 1,500. Each Program Officer manages an average of 50 active awards. 08/02/2005 Scientific and Financial Accountability Throughout Award Life NSF staff and consultants have expressed concerns and needs for: More staff and resources to oversee awards; More coordination between scientific and financial staff; and More formal award monitoring training. 08/02/2005 Scientific and Financial Accountability Throughout Award Life To address its workforce issues, NSF is: Contracting with a consulting firm to evaluate its workforce gaps and to recommend opportunities for improvement; Realigning its financial staff to focus more attention on its post award risk monitoring program activities; and Planning to offer award monitoring training through its in-house training academy. 08/02/2005 Scientific and Financial Accountability Throughout Award Life OIG assesses adequacy of NSF staff and resources to perform award monitoring as high risk. Annual audit of NSF’s financial statements identified the need for additional resources as a cause of NSF’s post award monitoring issues and recommended NSF dedicate staff to this effort. Outside consultant also identified lack of resources as a challenge to effective monitoring. 08/02/2005 Conclusion NSF faces increasing demands with limited resources. NSF must work smarter: Continue focusing attention on high-risk institutions; and Use other tools such as periodic telephone discussions and desk audits to monitor the majority of awards 08/02/2005 Conclusion Effective grant accountability takes a partnership! Program Officers and Administrative Staff; NSF staff and the OIG; and NSF and Awardee Institutions. Accountability in Science Funding Not legally binding Financial Framework in FP6 Workshop on Accountability in Science Funding Bonn June 1-2, 2005 Dr. Annette Doll-Sellen EC, Research Directorate General Accountability in Science Funding Not legally binding Contract Structure ¾Core contract (standard with specificities of project) ¾Annex I (technical tasks - the “project”) ¾Annex II General Conditions (applicable to every instrument) ¾Annex III Instrument specific provisions (specific to instrument) Accountability in Science Funding Not legally binding Contract structure & instruments Core contract Annex II Annex III IP Yes NOE Yes STREP CA SSA SMEs Yes Common Common None Accountability in Science Funding Not legally binding Contractors z New Every legal entity that contributes to the project (incl. Project Managers) z General Rule: Participant = contractor Every legal entity contributing to a project must have a contractual link with the Community Accountability in Science Funding Not legally binding Coordinator z A contractor amongst other contractors z No leadership z No additional rights BUT z Additional obligations z Administrative tasks: single entry point for communication, payments, reporting etc. Accountability in Science Funding Not legally binding Financing : what ? Community Financial Contribution (Arts 5 and II.24) Based on a calculation method Based on activities: Articles II.2 and II.25 Based on costs: Articles II.19, II.20 and II.21 Based on costs reporting models: Art II.22 Confirmed by an audit certificate: Art II.26 Accountability in Science Funding Not legally binding Financing: calculation method Grant for integration Grant to the budget Flat-rate Networks of excellence 9 Integrated Projects 9 Specific targeted research projects 9 Specific research projects for SMEs 9 Integrated initiatives relating to infrastructure 9 Actions to promote human resources & mobility 9 9 Coordination actions 9 Specific support actions 9 9 Accountability in Science Funding Not legally binding Financing: type of activity (a) zResearch and technological development (including innovation-related activities) zDemonstration zTraining zNew Consortium Management : costs reimbursed up to 100% within the limit of 7% of Community contribution Accountability in Science Funding Not legally binding Financing: costs 9 New principles: 1 - cost categories are replaced by conformity to contractors’ own accounting rules and legal environment 2 - simplify the eligibility criteria 3 - focus resources on the reality and the necessity of the cost, rather than on formality (cost categories) 9 Therefore, costs must be : Ö actual, economic and necessary for the project Ö incurred during the duration of the project (exception: costs of the final reports) Ö recorded in the accounts (or third parties) 9 and must exclude indirect taxes, duties, interests, costs reimbursed with respect to another Community project, and not give rise to profit Accountability in Science Funding Not legally binding Financing: cost reporting models (a) 9 FC: actual direct and indirect costs (not available for Coordination Actions and Specific Support Actions) 9 New FCF (variant of FC): actual direct costs + flate rate for indirect costs (20% of total actual direct costs, except costs of subcontracts - all instruments) 9 AC: actual additional direct costs + flat rate for indirect costs (20% of total actual additional direct costs, except costs of subcontracts - all instruments) Accountability in Science Funding Not legally binding Financing: cost reporting models (b) ¾ SMEs, non- commercial or non-profit organisations established either under public or private law, international organisations: FC/FCF ¾ Physical persons/Individuals?: AC mandatory ¾ Private companies (other than above): FC ¾AC: only for those non- commercial or non-profit organisations established either under public or private law or international organisations that do not have an accounting system that allows the share of their direct and indirect costs relating to the project to be distinguished. General Rule: a legal entity applies the same cost model in ALL contracts established under FP6 except that it may move from AC to FCF/FC or from FCF to FC (“one way ticket”) Accountability in Science Funding Not legally binding Reporting periodicity Reports and deliverables z The consortium will submit the following reports to the Commission: For each reporting period, 45 days after its end: a periodical activity report a periodical management report a report on the distribution between contractors supplementary reports required by Annex to this contract an audit certificate when required Accountability in Science Funding Not legally binding Payment modalities 9 Periodical pre-financing (based on the applicable reporting periodicity) 9 Periodical “final” payments if costs are certified 9 The Community financial contribution is paid to the coordinator on behalf of the contractors: the consortium decides on its allocation between the contractors (consortium agreement) Accountability in Science Funding Not legally binding What’s new in FP 7? Main new elements compared to FP6: z Annual budget doubled (EUR 5 billion ►10 billion) z Basic research (~ EUR 1.5 billion per year) z Simplification of procedures z Logistical and administrative tasks transferred to external structures
