AAU responds to a White House Office of Science and Technology Policy Request for Information (RFI) on “Accelerating the American Scientific Enterprise.” AAU urges the administration to expand university–industry partnerships, reject an “innovation tax” on university licensing royalties, reduce regulatory burdens, sustain high-risk/high-reward and AI-enabled science investments, and harmonize research security and merit-based grantmaking policies.
AAU appreciates the opportunity to respond to the Request for Information on Accelerating the American Science Enterprise. Our response to specific questions posed in the RFI are delineated below.
(i) What policy changes to Federal funding mechanisms, procurement processes, or partnership authorities would enable stronger public-private collaboration and allow America to tap into its vast private sector to better drive use-inspired basic and early-stage applied research?
Industry-academic collaboration in basic research provides significant advantages: industry gets access to basic research, talent, and scientific equipment it could not effectively access on its own, while academic research is informed by economic needs and societal benefits from the new knowledge generated. The federal research enterprise boasts several new or longstanding mechanisms to catalyze these partnerships, including the National Science Foundation (NSF) Engineering Research Centers, the Department of Energy (DOE) Bioenergy Research Centers, the cross-agency Manufacturing USA program, and others, as well as regional initiatives like the Innovation Engines and the Economic Development Administration (EDA) Tech Hubs. In addition, visioning and road-mapping efforts like the Department of Energy’s Basic Research Needs and NASA’s Civil Space Shortfalls initiatives help to identify directions for basic or early-stage research that can lead to technology breakthroughs and commercial payoff later.
As a system, these centers and initiatives have proven effective at yielding thousands of discoveries, inventions, licenses, spinoffs, and startups, while providing training and research expertise to generations of science, technology, engineering, and mathematics (STEM) students, researchers, and professionals. They are a major factor in the significant economic return produced by federal R&D investment. However, recent budget requests have sought to de-prioritize many of these initiatives. We urge you to sustain and expand support for these valuable activities, and to proactively work with the university, industry, and federal lab communities to identify best practices and means of improving or streamlining partnerships.
In addition, the administration should call on Congress to raise the basic research tax credit rate above 20% to strengthen incentives for business to invest in university and nonprofit basic research that drives long-term U.S. innovation and economic leadership. By proposing an enhanced credit targeted at industry-academic collaboration, the Office of Science and Technology Policy (OSTP) can position this change as a pro-growth, pro-competitiveness measure that leverages private capital to bolster America’s scientific and technological edge.
(ii) How can the Federal government better support the translation of scientific discoveries from academia, national laboratories, and other research institutions into practical applications? Specifically, what changes to technology transfer policies, translational programs, or commercial incentives would accelerate the path from laboratory to market?
United States Secretary of Commerce Howard Lutnick’s recent proposal to impose a 50% innovation tax on university licensing royalties earned from federally funded research should be firmly rejected. This proposal is inconsistent with the Bayh–Dole framework and counterproductive to the goals identified in this RFI. The current system of federal support for university research and development already delivers substantial public returns through new products, startups, jobs, and tax revenues, while university licensing income is statutorily mandated to be reinvested into research, education, compliance, and tech transfer operations. An innovation tax on royalties would weaken university capacity to patent and commercialize inventions, depress private investment and startup formation, and sharply undermine university-private sector collaborations and incubator programming, particularly at public and less resourced institutions. In the long run, this would shrink the pool of successful innovations, producing little net fiscal gain while jeopardizing U.S. innovation leadership.
Instead of pursuing an innovation tax on university royalties, we urge OSTP and the Office of Management and Budget (OMB) to build on the existing, bipartisan policy blueprint developed by NIST’s “Return on Investment Initiative for Unleashing American Innovation” (the Green Paper) during the first Trump administration. The Green Paper identified a robust menu of reforms to strengthen the tech transfer ecosystem and improve taxpayer return on investment. These include streamlining federal technology transfer regulations, clarifying march-in and intellectual property (IP) policies, expanding flexible partnering mechanisms (e.g., Cooperative Research and Development Agreements and other agreements), reducing administrative friction in licensing, enhancing Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs and other commercialization pathways, and improving data and metrics on the impacts of federally funded research. We recommend that OSTP and OMB explicitly revisit the Green Paper recommendations, direct agencies to implement high value, consensus items in coordination with universities and industry, and focus on measures that expand and accelerate commercialization rather than diverting the resources that currently sustain it.
Lastly, we encourage you to support the creation of an early-stage “phase 0” proof-of-concept research program to accelerate the movement of discoveries to the marketplace and increase the number and quality of high-tech start-ups resulting from federally sponsored research. The existing SBIR/STTR programs presume there is already evidence that specific research or technology has enough commercial value to attract further investment. In many cases, there is still a gap in the funding needed to push technologies across the chasm between demonstrable commercial value and successful commercialization. This gap discourages would-be investors from funding studies into the commercial viability of such university-based research advances, preventing universities and faculty entrepreneurs from moving new discoveries and technologies into the marketplace. Such a program would help university faculty to commercialize their research by providing them with additional resources and support to better understand potential applications and markets for their discoveries and to develop product development milestones and plans. An existing model for such a program exists in NIH’s Research Evaluation and Commercialization Hubs (REACH) program.
(v) What empirically grounded findings from metascience research and progress studies could inform Federal grantmaking processes to maximize scientific productivity and increase total return on investment? Please provide specific examples of evidence-based reforms that could improve funding allocation, peer review, or grant
As you seek to apply the findings emerging from metascience, our overarching recommendation is to find constructive ways to actively foster a robust community of practice in the areas of metascience, metrics, and evaluation. Federal agencies, institutions, and researchers have grappled for years with the question of how best to measure research outputs and outcomes. Relevant federal offices include NSF’s Directorate for Social, Behavioral and Economic Sciences; the National Center for Science and Engineering Statistics; and the Directorate for Technology, Innovation and Partnerships as well as the Government Accountability Office Science, Technology Assessment, and Analytics team; the Patent and Trademark Office; the NIH Office of Evaluation, Performance, and Reporting; and many others. Staff at these offices have a long engagement with questions of science metrics and evaluation. In addition, academic researchers at institutions across the country have built an extensive and growing body of work on metascience and present a valuable source of expertise.
We therefore encourage you to seek ways to strengthen the practice of metascience by empowering researchers in agencies and academia to continue refining the appropriate metrics and techniques for measuring the impacts of science, to build connections across domains through research fellowships and other talent exchanges, and to resolve questions of data access to enable research projects that might further enhance our knowledge of the scientific enterprise. Treating this as a priority will give funders and performers of scientific research – as well as taxpayers – a clearer view of returns on federal investment and how to enhance them, while providing better intelligence on overlooked and underfunded research opportunities. It will also ensure policymakers are adequately equipped to evaluate policy changes and funding mechanism reforms as they are implemented.
(vi) What reforms will enable the American scientific enterprise to pursue more high-risk, high-reward research that could transform our scientific understanding and unlock new technologies, while sustaining the incremental science essential for cumulative production of knowledge?
It is particularly important for government to pursue high-risk, high-reward (HRHR) research because its typical mix of high project failure rates and high-impact successes makes it uniquely well-suited for public investment. There exist multiple avenues for such research, including the HRHR program through the NIH Common Fund, and the various Advanced Research Projects Agency offices at the Departments of Energy, War, Health and Human Services, Transportation and across the Intelligence Community (IC). These programs champion exceptionally bold and innovative science that pushes the boundaries of research, yielding exactly the kinds of transformational advances the Trump Administration is seeking to promote. However, recent budget proposals have again sought to de-prioritize many of these programs. We encourage you to support these programs as part of a balanced research portfolio.
Beyond these specialized programs and offices, you may consider adding scientific risk level as an explicit criterion for awards in select funding announcements where appropriate, instructing grant reviewers to give greater weight to HRHR proposals than they may otherwise might in traditional reviews.
(viii) How can the Federal government leverage and prepare for advances in AI systems that may transform scientific research—including automated hypothesis generation, experimental design, literature synthesis, and autonomous experimentation? What infrastructure investments, organizational models, and workforce development strategies are needed to realize these capabilities while maintaining scientific rigor and research integrity?
We applaud the Trump Administration’s support for AI-enabled science as identified in the AI Action Plan and operationalized through support for the National AI Research Resource (NAIRR) Pilot, the Genesis Mission, and other activities. As you build out these efforts, we encourage you to consider universities as key partners given our research excellence, scientific domain expertise, data resources, and education mission.
As we have said in other public commentary, harnessing the AI-enabled science revolution at scale will require several elements including:
- Sustaining the scientific foundation to ensure a critical mass of domain expertise among S. scientists and engineers across a broad array of disciplines, who will be responsible for deploying and orchestrating AI tools, identifying grand challenges, and driving the scientific enterprise.
- Strategy development to understand scientific challenges, define goals, measure progress, coordinate resources, and chart novel directions for
- Fundamental AI research into AI principles, theories, and novel techniques for reliability, trustworthiness, explainability, and
- Applied research into effective, scalable tools, models, and agents that can be translated and seamlessly incorporated into discovery science workflows.
- Computational infrastructure and access upon which to build, train, and operate AI models and
- Data resources and infrastructure to ensure S. researchers have access to the raw material of AI-powered discovery.
- An AI-capable scientific workforce with opportunities for learning and research
- Pathways to multi-sector partnerships as no single sector has the capacity to fully and effectively own and drive the AI-enabled science
We would encourage a few specific steps:
Improve access to secure data sets: There continues to be a pressing need to improve researchers’ access to the vast trove of federal data, much of it sensitive. To that end, an important activity is the National Secure Data Service (NSDS), currently in its demonstration phase, and supported by NSF. The service is intended to dramatically streamline access and linkages to federal data resources. We urge you to work with Congress to ensure the project continues and is adequately resourced to scale appropriately.
Update the Federal Data Strategy: This strategy was initiated under the first Trump Administration, to develop a strategy that modernizes federal data practice and policy with an eye to AI readiness. This is likely an activity that would occur under the Genesis Mission auspices, in partnership with the Federal Chief Data Officers Council and the Chief AI Officers Council. If so, we would applaud and encourage it.
Fully fund the National AI Research Resource (NAIRR): As you know, NAIRR is critically important for connecting researchers with public and private computational resources and testing platforms as well as datasets, education and training, software, and partnerships. The project is also well-positioned to support research into smaller, more specialized, and energy-efficient models tailored for AI-enabled science by domain. Considering the potential economic upside of AI-powered R&D, the funding levels recommended by the NAIRR task force of $440 million per year represent smart and sound investment. Further, as you pursue a broad AI infrastructure strategy, we encourage you to continue supporting advanced computing centers at universities, which serve as important sources of specialized access for researchers and play a vital role in advancing discovery. Universities continue to face a massive computation gap with other sectors.
Invest in discipline-specific AI training: On the scientific workforce front, an effective federal AI strategy will take discipline-specific approaches to curriculum development, boot camps, and other application-oriented AI training, as well as fellowships and scholarships. NSF, NIH,and DOE are particularly well suited to lead these efforts among the academic science community, but other agencies should play a role as well. We encourage you to also support mobility between academia, national labs, and industry to maximize opportunities for students, and to ensure that researchers stay mutually aware of needs and opportunities across sectors. These can be achieved through embed programs, apprenticeships, and externships.
Understand the talent market: Lastly, federal efforts to develop an AI-ready scientific workforce would benefit from a clear understanding of the human capital landscape. We encourage you to direct federal statistical agencies to develop a strategy for collecting and assessing data related to the AI workforce, and to work with external stakeholders to develop a talent roadmap that addresses emerging skill needs and talent gaps.
(ix) What specific Federal statutes, regulations, or policies create unnecessary barriers to scientific research or the deployment of research outcomes? Please describe the barrier, its impact on scientific progress, and potential remedies that would preserve legitimate policy objectives while enabling
Research universities often face duplicative and inefficient regulations that are not sensible or scaled to risk. While many of these regulations and reporting requirements are well intentioned, the cumulative burden imposed by the many layers of regulations is unsustainable. Such regulations also reduce faculty productivity by diverting time from research and teaching.
AAU encourages the administration to constitute the Research Policy Board, as directed by Section 2034 of the 21st Century Cures Act (Public Law 114-255). This board is charged with coordinating and improving regulations and policies, identifying policy and regulatory gaps and challenges, and conducting ongoing assessments of regulatory burdens to enhance efficiencies and optimize the federal investment in research.
Lastly, we encourage you to continue to support science-based, merit-based decision-making in the awarding of federal research dollars. Recent administration actions – namely, the August 7 executive order on federal grantmaking – would seem to replace the merit-based review system with decisions by political appointees. Such a move threatens to undermine the scientific enterprise and the aims of Gold Standard Science, by adding a layer of bureaucracy that will diminish the role of quality and excellence in science. The merit-based system has won the United States its place as global science leader, and we should ensure it continues.
(xiii) How can the Federal government strengthen research security to protect sensitive technologies and dual-use research while minimizing compliance burdens on researchers?
Universities take seriously the threats posed by foreign adversaries and have taken steps to secure and protect the research they conduct. Since 2018, significant progress has been made to develop research security policies within the federal government and at institutions. National Security Presidential Memorandum 33 (NSPM-33), announced during the first Trump administration, instituted broad requirements for disclosure and research security infrastructure for research recipients. Continued implementation of NSPM-33 and harmonization of research security policies across federal agencies is essential to safeguarding federally funded research from foreign influence, ensuring national security, and maintaining the integrity of the U.S. research enterprise, while also minimizing compliance burdens. There are several actions outlined below that the federal government can take to address research security and minimize compliance burdens.
Convene the interagency research security working group: Key to maintaining focus and coordination on harmonizing agency research security policies and definitions, OSTP should revitalize, maintain and regularly convene the interagency research security working group established under the National Science and Technology Council and authorized by National Defense Authorization Act of 2020 (P.L. 116-92) to ensure continued implementation of NSPM-33 and harmonization of agency research security policies and definitions.
Provide consistent research security policies across all federal agencies: Through the interagency working group, it is important to maintain consistent research security policies and definitions to limit agency variation. Duplicative or inconsistent requirements add to the compliance burden of researchers and institutions. OSTP and the working group should revisit NSPM-33 research security program guidelines to provide more clarity and harmonization of requirements across federal research agencies, including standards for institution’s foreign travel policies and a consistent definition for covered individuals. According to a recent National Academies of Science, Engineering, and Medicine (NASEM) report “the U.S. research security landscape remains fragmented, requiring universities to reconcile overlapping or conflicting rules from multiple agencies. Researchers continue to confront inconsistent disclosure forms and systems—for example, often re-entering data already housed in the Science Experts Network Curriculum Vitae (SciENcv) because agencies have not uniformly adopted the agreed upon ‘common forms’ and SciENcv system.” Standardized policies reduce administrative burdens for researchers and institutions, allowing them to focus on innovation while ensuring compliance with clear and consistent requirements.
Create common principles for a risk-based approach: The use of a risk-based approach is key to limiting scope and undue burden across all research areas. Accounting for risk through factors such as the type of research being performed and/or where the research is taking place can be critical to identifying and mitigating the most significant threats and minimizing compliance burdens to the areas of greatest concern. Federal research agencies have independently established their own risk-based review procedures, which has led to a complex web of review standards. Consistent with NASEMrecommendations, through the interagency working group, OSTP can convene agencies and help develop common principles and elements for all agencies to adhere to in their risk review process. This would help provide greater consistency across agencies while still allowing each to tailor policies and practices that account for factors unique to their specific research landscape.
Provide targeted protections when necessary: Existing controls and vetting processes for “sensitive” research already allow the federal government to classify projects, impose export control restrictions, limit information sharing through Controlled Unclassified Information (CUI), and require additional vetting for foreign students and scholars. To remain agile and protect U.S. competitiveness, any restrictions or prohibitions must carefully consider the potential consequences to U.S. innovation. When protections are necessary, we must ensure they are narrowly tailored to address specific concerns. Blanket restrictions on all types of research or outright prohibitions on certain types of research risk undermining our ability to compete globally, attract and retain talent while also adding compliance burdens to institutions and university researchers.
In addition to the comments provided above, AAU also supports the comments submitted by the Association of Public and Land-Grant Universities, the Council on Government Relations, and the American Council on Education.