The Independent Review of Research Bureaucracy, led by Professor Adam Tickell, is a timely and welcome report on the current status of bureaucracy in the UK research funding system.
Overall, Wellcome is supportive of the seven principles the report recommends should underly the future direction of research bureaucracy. However, for funders specifically, reduction in bureaucracy must be balanced against their right and duty to ensure the substantial funds they award are disbursed and protected appropriately. Our aim is to balance sometimes competing needs to ensure unnecessary bureaucracy does not hamper researchers and organisations from making progress towards achieving our combined strategic objectives.
The report has many important recommendations for government funders in particular, and we look forward to the Government’s response to the report. There are also relevant messages for the sector as a whole and in our response below we focus on the specific recommendations most relevant to Wellcome.
Grants assurance is a necessary activity to ensure funds provided for research are spent on the purpose for which they were awarded, and in compliance with the conditions of the awarding body, particularly where the awards are high value. We recognise that grants assurance brings a burden on organisations, researchers and funders, and that there have been additional requirements brought about either by changes in the funding environment, such as data security, or measures to bring about changes to research culture, such as tackling bullying and harassment. We also acknowledge that policies can vary between funders, for example open access, which makes it harder for organisations to ensure compliance with the policies of every funder.
In 2019 Wellcome founded a small informal group – the Grant Funders Policy Group – with other major UK health research funders to discuss policy development and implementation. This has worked well to increase an understanding of policies and their rationale as they relate to each funder and to align policies where possible. Examples include discussions on bullying and harassment, continued professional development, Covid supplementation and currently on inflation and environmental sustainability. It should be noted that it has no decision-making authority and the individual funders’ strategies influence how close the alignment can be.
A current project sponsored by the Grant Funders Policy Group, led by Wellcome and due to be delivered in pilot form in 2023, is a mechanism to assess whether a funded organisation is compliant with funders’ policies. Whilst currently intended to provide an understanding of policy compliance and support improvements, it could be incorporated into a ‘self-certification’ mechanism in the future if desired (recommendation 4). Underlying principles for the model include collecting data once, providing access to all UK funders and, in the longer term, streamlining or removing burden from other parts of the research funding process. This project will take into account other current initiatives such as the ARMA/UKRI due diligence project.
Recommendations 1 and 2: increase co-ordination and reduce burden of grants assurance.
As noted in the report, there have been some efforts to undertake joint audits of awards made to UK universities across UKRI, Wellcome, NIHR and others. However, different funders have different audit approaches, varying from a detailed assessment of individual transactions on an award to assessment of the controls around these transactions and the organisation’s approach to risk management. Wellcome favours the higher-level assessment of controls and risk, and while we use information previously gathered where possible, it currently does not always fulfil our needs.
Further discussion would be required to adopt a joint audit approach across funders, which Wellcome is open to. Institutional control environments are understandably not uniform and there is an opportunity for funders to understand the requirements and constraints within the HEI sector and adapt our approaches where possible. It is important to note, however, that Wellcome (like many other funders) does not only work within the UK HEI sector but across independent research institutes and many other countries.
Whilst not leading to a specific recommendation, we have noted the strength of the statement that terms and conditions should only change during an award in exceptional circumstances (page 26). It is not clear if this is referring to standard terms and conditions used for the bulk of awards, or to the relatively small number of non-standard terms and conditions such as those used for partnerships. For the former, Wellcome’s approach is to bring consistency to managing its active portfolio and we must evolve our terms and conditions to ensure they remain fit for purpose. If an organisation has received a recent award from Wellcome and is compliant with those conditions, then complying for all current awards should not be problematic. It is not practical to have multiple sets of conditions live at any one time and we consider this would bring greater confusion and bureaucracy.
Applying for funding
We agree that applying for funding is a significant task and recognise many of the issues highlighted in this section. Wellcome continually evaluates its application processes, including the information requested from applicants.
Wellcome trialled a new model of gathering information from the applicant and organisation only at the relevant point(s) required during the assessment process when we introduced Investigator Awards a decade ago (recommendation 9). However, we discontinued this process for a number of reasons:
- It increased the administrative burden on the funder substantially.
- Organisations and applicants reported that all the information to submit a grant application was collated at the start of the process. Applicants were not supportive of repeated requests for information during the assessment process for a single application.
- Issuing of awards was delayed as it took time to obtain the final cost information required.
We also agree with only using peer review where there is clear benefit and that, after a certain point, increasing the number of reviews does not make the assessment better. For the majority of our funding schemes or calls we have a shortlisting step carried out by external experts prior to interview. Written expert review is only sought on shortlisted applications, reducing the burden on the scientific community and funder administration.
We support the principle of only asking for the information required to make an assessment or for audit and regulatory purposes. We continually review our forms to prevent unnecessary expansion, however sufficient information must be submitted to support due diligence and a robust review process.
During the implementation of our new strategy in 2020, we reviewed our processes and introduced a number of changes, some of which were directly related to equity, diversity and inclusion (recommendation 12). These include:
- Adoption of the narrative CV, in alignment with other major funders.
- Standardising questions in forms and removing questions where the information has not or will not be used in the future.
- Providing only the research proposal to those asked to provide a written review.
- Removing the requirement for letters of support, retaining them only where needed for due diligence (such as ensuring space and facilities will be made available) or policy compliance (for example, commitment to career development of the applicant).
We also regularly monitor the representation and diversity of our applicants, award holders and committee members and currently provide anti-racism training for chairs of our major committees; we intend to expand and broaden this provision in the near future. Capturing EDI information can be challenging; we currently request this at the point of registration on our system, although it is not mandatory.
We have begun a review of the operational processes introduced with our new funding schemes which will report in mid-2023 and bureaucratic burden will be part of that review.
We are also reviewing our processes to ensure they do not disadvantage applicants from minoritised groups or poor resource settings. We know that Black British researchers are underrepresented in our research funding and recently announced two steps we will explore to improve this situation – positive action in decision-making and a dedicated stream of funding; read more about our anti-racism programme. Whilst not directly related to research bureaucracy, it demonstrates our commitment to EDI.
Recommendation 9: funders should explore using a two-stage process more frequently.
A two-stage application process typically includes a preliminary application. Wellcome supports using preliminary applications only for demand management, where we anticipate an unmanageable volume of applications, or where there is a very specific strategic drive. A single stage process means that the applicant only needs to prepare and submit a proposal once and their ideas are evaluated fully by expert reviewers, rather than by funder staff who may not collectively have sufficient expertise across the breadth of a remit, with the risk of inconsistency and bias in the assessment of preliminary applications. Additionally, preliminary application stages extend the time taken to reach a final decision for successful applications. As detailed above, we have also trialled a multi-stage application process.
Recommendation 10: We are open to exploring the suggestion in partnership with others of standardising language between funders to provide definitions of key terms, such as sponsor.
Grant implementation and in-grant management
Wellcome aims to minimise bureaucracy post-award. Research can take unexpected turns and, provided the purposes of the award are adhered to, our approach is to allow researchers the flexibility to achieve this as they see fit.
We welcome the report’s endorsement of our policy to allow 12 months from point of award to start date. Award holders may also move funds between awarded headings, only requiring major changes to be notified to us. No-cost extensions (where justified) have always been an allowable part of awards at Wellcome and this will remain in place (recommendation 16).
During 2023 we will implement an on-line, light-touch mechanism for award holders to request no-cost extensions. We will additionally review how we track project progress and outcomes.
Digital platforms and information sharing
The report rightly highlights the benefit of interoperability of application systems and the use of unique identifiers to facilitate a ‘once only’ and collaborative approach to collecting information. The report also notes that it is not always appropriate or legally permitted to share information with other bodies and therefore, whilst we are supportive in principle, we are required to adhere to the relevant regulations.
Wellcome chose to adopt ResearchFish rather than implement its own outcome assessment system, the main driver being its broad adoption across other funders, thereby removing the burden of additional requests for outcome information from organisations. The system would benefit from a review and simplification, which Wellcome would be open to take part in with other stakeholders.
Wellcome is due to launch its new grants management system during 2023 which is being built on a market leading platform, has end-to-end functionality, and supports APIs. The new system integrates several standard products which may be updated independently and allows greater flexibility. As noted above, we are currently reviewing how we track project progress and outcomes and will take a critical approach to what is requested, using the principles of necessity, utility and consistency (recommendation 23).
Wellcome is supportive of transparency and agrees that good communication plays an essential role in the partnership between funders, researchers and organisations.
There is an opportunity to work more together as funders to give a level of clarity in communication channels and revisit the forums that already exist.
Recommendation 32: funders should ensure enough time is left between announcement of calls and application deadlines.
We aim to have all information needed by applicants and funded organisations on Wellcome’s website at the point of launch of a funding call. Our website is a critical mechanism for communication and all our funding opportunities are listed with accompanying timelines. Funding calls are socialised also through social media and networks. Application deadlines and processing timelines are established considering the time needed for applicants to prepare (who often are not UK-based) and the desire for rapid decision-making, in the context of often urgent strategic objectives.
We regularly produce a bulletin detailing changes to policies and processes that is sent by email to those who have signed up to receive it (this can be done directly or through our website).
Research offices are a key stakeholder group in the research community and Wellcome intends to expand its links with them to improve communication and mutual understanding of each other’s operations.
We are also designing better access to information for research offices into our new grants management system due to launch in 2023, including for award letters. It should also improve the efficiency of requests for further information from research offices for due diligence purposes.
Recommendation 28: wide-ranging consultation should be undertaken before the introduction of additional requirements.
Wellcome is an agile organisation and whilst the concept of widespread consultation is understood, it often is bureaucratic (as the report acknowledges) and slow, with a tendency for the outcomes to be less impactful and risk averse. However, we agree that communication about changes is important and using a stakeholder group is of benefit. We have seen this during our development of a continual professional development policy where we gained valuable insight from a group of organisations and funders alike which we incorporated before launch to produce an improved final policy.
We hope our response provides a useful sense of the recent steps we have taken to reform research bureaucracy, what our experience has taught us about these important issues and where we intend to focus our future activity to support further improvements.
Wellcome is committed to continual improvement and working in partnership with the research community in all its activities, including research bureaucracy. We welcome feedback on how we can improve and will continue to critically assess our own processes and our own requirements as well as work with other funders and funded organisations to optimise research bureaucracy for all.