Kauffman Foundation letter of support

June 18, 2009
Office of Information and Regulatory Affairs of OMB
Attention: Desk Officer for National Science Foundation
725 17th Street, NW.
Room 10235
Washington, DC 20503
And
Suzanne H. Plimpton
Reports Clearance Officer
National Science Foundation
4201 Wilson Boulevard
Suite 295
Arlington, Virginia 22230
Sent via email to [email protected]
RE: Comments on the National Science Foundation’s Survey of Research and
Development Expenditures at Universities and Colleges, FY 2006 through FY 2008
(FR 24042 or OMB Control No: 3145-0100)
The Kauffman Foundation, as the nation’s largest foundation devoted to furthering
understanding of entrepreneurship, has a strong interest in high-quality statistics on
topics such as R&D, startups, and commercialization of innovations. As such, we
enthusiastically support the redesign proposed by the National Science Foundation
for the Survey of Research and Development Expenditures at Universities and
Colleges.
The National Science Foundation has been a leader in recognizing the need to
measure both basic scientific activities as well as activities related more to later stage
commercialization. The current redesign places particular importance on the
introduction of a test module on “University Intellectual Property and
Commercialization.” As this is the module which has received the least amount of
testing but which holds great potential for improving understanding of the role of
higher education in bringing inventions to market and supporting a host of other
aspects of economic development, we will focus our comments on this module.
First, we would highlight that we have been involved in a multi-year dialogue led by
the Association of University Technology Managers (AUTM) related to developing
new metrics for technology transfer. This project has resulted in a draft proposal for
an “Institutional Economic Engagement Index” which we include as Attachment 1 to

our letter. As the discussion from AUTM in the attachment highlights, and we feel is
largely reflected in NSF’s proposed survey, measuring a university’s engagement in
the innovation ecosphere is a complex topic. From this document, we would like to
specifically highlight the measures which AUTM recommends would conceptually
compose their ideal “Technology Knowledge Transfer” activities:
1. Number of agreements signed by institution to enable external use of
institution technology
2. Number of companies within x miles (or State) of institution who have a
contractual relationship with institution regarding technology use or
development
3. Number of new companies / year who have new contractual relationships with
institution
4. Number of recurring companies / year who have contractual relationships with
institution
5. Number of consulting agreements / year with faculty or staff from institution
6. Number of faculty involved in consulting / research / other knowledge transfer
activities with community
7. Number of companies launched / year associated with institution technology
(as evidenced through some type of contractual relationship)
8. Number of start-up companies still in business, and their employment,
associated contractually with institution
9. Institution research projects which have strategy for distribution of research
assets
AUTM and other leaders we have engaged with would not suggest any one agency,
federal or private, could collect all of the data listed. However, from this list, the
current NSF pilot survey instrument successfully appears to gather data on topics 1,
3, and 7 completely; to partially gather data on topic 2; and to not address topics 4, 5,
6, 8, and 9.
One advantage of the National Science Foundation’s collection of data on technology
transfer/commercialization activities is that it collects more unbiased data from the
entire population of universities with a research function. That said, the proposed
NSF survey would be well-advised to address as many of its statistics as possible
from a local/regional lens. For example, topic 2 on the number of companies within a
region which the university has a relationship is not present in the current NSF survey
and is one of keen interest to most universities and state and local policymakers. In
most cases, we feel this topic would be most easily addressed by asking about
companies within the state (or multiple states) which a university inhabits. On topic
4, small modifications to the survey could gather data on number of recurring
companies the university has relationships with which would have been noted in

previous years once a baselines was established. Topics 5, 6, 8 and 9 are not
appropriate topics for NSF to gather metrics.
In addition, we would respectfully suggest that further consideration be given to the
following subjects in the survey at the next available review:
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Question 2
o The use of the phrase “U.S. patent technologies” seems somewhat
ambiguous. If the reference is to activities to/from the U.S. Patent and
Trademark Office, we would recommend using that language. If the
reference is instead to patent activities which occurred by university
personnel or involving the domestic offices of the university, we would
recommend using that language. Both issues are non-trivial but we
suspect the first interpretation was the one meant. Additionally, to the
extent that clarity can be given to possible international campuses or
facilities of a university and if they should be included in reporting, we
would recommend doing so although this does not seem to be a
frequent problem.
o The categories listed under “Include patents for:” are different from the
column headings on the question. This should be consistent in order
and phrasing.
Question 4
o Is there any desire to know of the overlap in patents on the same
invention which potentially could be counted in questions 2 and 4? This
may not be an issue but my understanding was that the same invention
could be patented in multiple locations.
Question 7
o This question is a good one in that it looks specifically at startup
businesses. That said, it would be good to give more guidance in
definitions used. From the Kauffman Firm Survey, we know that for a
nationally representative sample of businesses which were four years
old, seven percent of firms that report having a “competitive advantage”
in their business say that it is related to teaming up with a college or
university? For forty-five percent of these firms, this teaming with a
university is a key component of their perceived competitive advantage.
We say that only by way of encouraging further development of
questions 7 and 8. There appear to be many young companies, not
perhaps still purely startups, which are highly engaged with universities
in developing their business activities. Currently the questions get at an
aspect of possible relationships here but many startups take multiple
years to develop and are nurtured by universities in complex ways.
Question 9

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o This continues the focus on startups but this question would seem not
nearly as valuable without knowing the distribution of overall companies
which the university has licensed technology two in each area which the
question currently lists.
Question 10
o Is the use of “technology-related” in the question meant to screen out
any particular type of revenue which universities would likely otherwise
include? If so, then specifically listing different types of revenue which
should be excluded would be helpful. If not, then perhaps that phrase
could be dropped.
Question 11 and 12
o The placement of these questions would seem better after question 2.

On the remainder of the survey outside of the proposed module, we have some
doubt that “foreign sources” of R&D expenditure are currently tracked by universities
in question 2. And on question 20, clarification that institutions should include total
dollars in the award regardless of if the money was received in FY2009 would seem
helpful.
Lastly, we are assuming data will be publicly available and tied to individual university
names unless it is otherwise stipulated on the documents. In particular, no part of the
“University Intellectual Property and Commercialization Module” is currently marked
“confidential.” We agree with this direction.
This is a worthwhile redesign and we remain open to any assistance we can provide
to help.
Sincerely,

E.J. Reedy
Manager, Research and Policy
Kauffman Foundation
[email protected]
816.932.1078
cc: Lynda T. Carlson, National Science Foundation
John E. Jankowski, National Science Foundation