Please help us in responding to an NIH request for information on inclusion at institutions

Please help us in responding to an NIH request for information on inclusion at institutions

The Board of Directors at Future of Research has been preparing a response to the Request for Information (RFI): Institutional Accountability to Promote Inclusive Excellence (Notice Number: NOT-RM-19-001) issued recently by the National Institutes of Health, and due by June 14th 2019. However we are looking for additional input from those wishing to help us with their thoughts and critiques.

 

We are looking for help not only in the form of others submitting comments, but also in helping to craft our response. In promoting the call for responses, we experienced a great deal of frustration from the community – which we share – about the constant discussion about such issues without any concrete actions. We’d like to try to give voice to those frustrations, and channel it into some concrete push for action, if possible.

 

Therefore we have placed out draft response to questions below; we plan to do more work on preparing a final response for next week. We would be extremely grateful for any criticism you have – you can comments on this post, on social media, or email info@futureofresearch.org, and we are happy to give voice to frustrations you have, particularly if you would not feel comfortable making such comments yourself. Ultimately we hope to provide information that compels NIH to ultimately take action, and particularly to recognize the power that it has to compel institutions to do so.

 

In summary, NIH is looking for the following information:

“Information Requested
NIH seeks input from key extramural community stakeholders, including academic institutional leadership, biomedical faculty, and interested members of the public on strategies to collaborate with institutions on achieving inclusive excellence, scientific environments that can cultivate and benefit from the full range of talent, by catalyzing sustainable institutional accountability. Topics that could be addressed include, but are not limited to, the following:

  • Institutional programs and approaches that have been successful in reducing isolation, increasing community building, and fostering career advancement for early-career faculty, including those from diverse backgrounds, such as groups underrepresented in biomedical research
  • Institutional mentoring programs that support faculty development, retention, and career success
  • Faculty-level cohort-model approaches that are institution-based or distributed across institutions
  • Data-driven strategies to assess and manage institutional equity and diversity
  • Capacity for institutional support of early-career scientists, including start-up packages, research, lab space/equipment, and salary
  • Role of partnerships between institutions toward reducing isolation, increasing community building, and fostering career advancement for early faculty
  • Any other comments or recommendations for NIH to consider with respect to programmatic efforts to collaborate with institutions on achieving inclusive excellence through a cohort-hiring/mentoring approach with an emphasis on institutional accountability”

 

Our draft response follows:

 

FoR Draft Response to NIH RFI: Institutional Accountability to Promote Inclusive Evidence

 

 

  • Institutional programs and approaches that have been successful in reducing isolation, increasing community building, and fostering career advancement for early-career faculty, including those from diverse backgrounds, such as groups underrepresented in biomedical research

 

 

  • Institutional mentoring programs that support faculty development, retention, and career success

 

 

  • Faculty-level cohort-model approaches that are institution-based or distributed across institutions

 

We have currently combined responses to the first three sections, before parsing out into the respective appropriate responses. If you know of other examples, we would be very glad to hear about them!

“For example, the University Corporation for Atmospheric Research (UCAR) created a diversity training program called UNEION (UCAR|NCAR Equity and Inclusion); the Program for Early Career Excellence (PECE) at Rutgers; faculty boot camps to acclimate early career scientists e.g. at UMBC; the Launching Academics on the Tenure-Track: an Intentional Community in Engineering (LATTICE) effort and as we have discussed in the responses to previous RFIs, Howard Hughes Medical Institute’s Hannah Gray Fellows Program could be used as a point of comparison.”

 

 

  • Data-driven strategies to assess and manage institutional equity and diversity

 

“Currently data-driven strategies are being used across institutions to create more career transparency; we are not aware of strategies to manage equity and diversity.”

 

 

  • Capacity for institutional support of early-career scientists, including start-up packages, research, lab space/equipment, and salary

 

“The first concern is to clarify what is meant by an early-career scientist, or to encourage NIH to instead talk about all early career researchers e.g. graduate students and postdoctoral researchers, instead of only about investigators they fund directly. A major barrier to diversification of the pool of investigators is the postdoc-to-faculty transition (See https://elifesciences.org/articles/21393, https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0190606), and the lack of attention that institutions, including the NIH, pay to the population who are pre-independence, is a major factor.

 

To address this, we have a number of suggestions. For example, NIH could consider ensuring greater institutional accountability for how postdoctoral researchers are being supported and retained. NIH could report on the results of its ACD Working Group on provision of NRSA benefits – we have identified that many researchers are exiting the workforce because they cannot afford to stay within it, and one reason could be that researchers who receive NRSA awards are losing their health benefits because of an arbitrary change from “staff” to “trainee” status, purely because of where the funding supporting them is derived from. NIH has identified that this is a problem (see slides 15 and 16 https://www.nigms.nih.gov/about/council/minutes/Documents/LUND_272017_final.pdf) but it is unclear what actions they are taking, or whether they are holding institutions accountable for this disparity, which discourages applications for awards. Especially as not all institutions receiving NRSA awards do take away benefits from NIH NRSA awardees, we urge NIH to focus on the population of pre-investigator status early career researchers that NIH supports. Early Stage Investigators emerge from this population, and attention must be paid to it by NIH if they are to address the problem of promoting inclusive excellence successfully. Many institutions cite NIH as the barrier to changing these policies, while we have received assurances from NIH staff that there are no legal barriers that exist. A clear answer from NIH on issues such as these would be appreciated.

 

As we have discussed in previous NIH RFIs on this topic, key strategies to address this should focus on aiding the transition to faculty positions; but also on retention and on incentivizing changes to the cultural norms of academe to ensure that people from these populations are not only present, but thrive. As we discussed in a previous RFI to NIGMS on this topic, a mechanism that has aided the postdoctoral-to-faculty transition is the K99/R00 mechanism which is a fundamental starting point for to consider utilizing specifically for those from underrepresented populations, such as the BRAINS Diversity K99/R00 (https://grants.nih.gov/grants/guide/pa-files/PAR-18-813.html). To address retention, institutions looking to attract this talent that such a transition mechanism could identify must meet certain criteria, including having diversity and mentoring plans in place, as well as active efforts to seek to retain faculty from underrepresented populations, including but not limited to fostering an inclusive environment, which provides mentorship and does not result in faculty from underrepresented populations carrying out an undue, burden of service (i.e. the “minority tax”). There could be a mandatory reporting requirement where faculty rate the institution for these cultural disconnects, support, etc.

 

Aggressive university start-up packages without fund expiration dates (that are not simply replaced by the “R00” component of a K99/R00-like mechanism) and standardized coverage of moving expenses, coupled with continual opportunities for seed funding (that are not just provided at time of hire but instead provide opportunities for more sustained financial investment) should be a considered requirement for NIH to expect of recipient institutions, to ensure that the institution is as committed to the investment in the investigator as NIH. Recognition of service carried out by faculty in tenure and promotion should also be demonstrated by an institution, so that this labor is rewarded and factored into tenure decisions, as this work is more often carried out by women and minorities, but does not receive the recognition that it deserves in research departments. In the NIGMS T32 (PAR-17-341, https://grants.nih.gov/grants/guide/pa-files/par-17-341.html) the review criteria for institutional and departmental commitment to the program highlight institutional policies that should be in place to score highly on the grant. Questions like these should be written into potential training/transition grants to motivate institutions to change their promotion structure. Similarly, peer-to-peer/cohort hiring and senior mentorship plans should be in place and demonstrated to NIH as a condition for receipt of funds by an institution.”

 

 

  • Role of partnerships between institutions toward reducing isolation, increasing community building, and fostering career advancement for early faculty

 

“Federal Funding from the NSF Advance program has created partnerships between institutions.

 

There could also be a greater role played in supporting the early career researcher population between institutions and scientific societies, as we have discussed elsewhere in the context of postdoctoral researchers and career development (https://peerj.com/preprints/27568/).”

 

 

  • Any other comments or recommendations for NIH to consider with respect to programmatic efforts to collaborate with institutions on achieving inclusive excellence through a cohort-hiring/mentoring approach with an emphasis on institutional accountability

 

“While commending NIH for taking steps to address this issue from the perspective of greater institutional accountability, Future of Research would like to take this opportunity to communicate increasing frustration from early career stakeholders at the continuous inability of NIH to promote and enforce institutional change, and the extreme skepticism that this RFI, as with other RFIs previously which we have made reference to above, will actually result in any change in NIH’s behavior. In constructing a response to this RFI, and urging others to do so, we received an overwhelmingly skeptical response that any change will actually occur. NIH should pay attention to the breakdown in trust between it and the community of researchers it depends on to fulfill its mission to the nation.

 

As concrete examples of skepticism that NIH can actually effect change, the NIH has used repeatedly used the term “legal barriers” as a reason for inaction. These legal barriers, upon closer study, either do not appear to exist (for example, the NIH have been unable upon further request to provide evidence for the NGRI working group’s claim that foreign researchers cannot be supported on K award or NRSA mechanisms) or NIH has not taken basic steps to address them (for example, in the case of sexual misconduct, NIH has not disclosed whether they discussed changes to the Code of Federal Regulations with Health and Human Services, in the 2 years since writing about the urgent action NIH would take in a major journal).

 

Despite this being the 50th anniversary of “The Invisible University” report, and Dr. Collins already having received a report from the Biomedical Workforce Working Group in 2012, at the Advisory Committee to the Director’s meeting discussing the final recommendations of the Next Generation Researchers Initiative, Dr. Collins insisted that we were “just beginning to diagnose” the problems facing this population. These problems, and the actual barriers to solving them, have been evident for some time, and the community appears to be losing patience with this response. These examples stand in especially stark contrast to the swift and decisive actions NIH and institutions have taken to supporting Congressional calls to remove foreign influences from biomedical research in recent months.

 

We would like to point out that, while efforts at requesting more information from stakeholders to get a qualitative idea of the landscape might be useful in designing and implementing next steps for change, it bears questioning whether the NIH has the constitutional power to enforce their policies at the institutional level, given their repeated admissions of their legal inability to do so, and so whether responding to this RFI is actually a constructive use of the community’s time and efforts. We suggest that, should the NIH really have the commitment to drive these types of changes, they do not rely on institutional self-interest to drive these changes, and instead envision the best way, within their own legal purview, to enforce institutional compliance with standards and transparency that have long been recommended. Should even this be outside of NIH purview, we endorse the creation of a central oversight body or committee, such as the Biomedical Research Enterprise Council (BREC) suggested in the NASEM report “Breaking Through” (https://www.nap.edu/catalog/25008/the-next-generation-of-biomedical-and-behavioral-sciences-researchers-breaking), to discuss how to fix the problems that NIH cannot or will not fix.

 

Solving the issues of the research enterprise is certainly not NIH’s sole responsibility. However, like many other stakeholders in the biomedical enterprise, NIH has a history of taking far less responsibility than it should, and passing responsibility to research institutions, who in turn will pass it back to NIH. If NIH actually holds institutions accountable for promoting inclusive excellence, that will be a constructive use of NIH’s power to take responsibility in its sphere as stated by NIH itself in this RFI, “Because previous approaches that focus on individuals have only slowly “moved the needle,” targeting systemic change through NIH-funded institutional transformation is necessary.” We expect the NIH to be responsible in delivering on the expectations they set up in their stakeholder populations, and the use of a word like “accountability” in this RFI sets a bar that is different to what we’ve seen in the past from them.

 

Approaches employed by ALL stakeholders should attempt to resolve cultural disconnects within the research enterprise, and resolve underlying issues, including but not limited to:

 

  • Financial insecurity – e.g. by ensuring that postdocs are paid salaries consistent with repeated recommendations, and that attempts are made by institutions and NIH to reduce training times;
  • Mental health – e.g. giving postdocs access to institutional student health and counseling services;
  • Feeling of isolation – e.g. through mentoring and peer-support networks at institutions and in scientific societies; with time out of lab mandated and funds provided to support efforts adequately, and with requirements for receipt of funding conditional on such support networks being demonstrable to NIGMS;
  • Work/life balance – e.g. setting realistic time limitations similar to medical residents (particularly given that institutions track vacation time, but not overtime);
  • Pressure to publish in certain journals – e.g. supporting the use of preprints and peer review training activities that recognize the scholarship of researchers and not an indirect measure of a journal’s “impact”;
  • Funding Insecurity – e.g. provide postdocs with training and control of funds/funding through fellowship mechanisms, including grant writing training and fund management, rather than suppressing potential independent research paths by placing them on another investigators research grant, fulfilling another investigator’s aims
  • Lack of adequate mentoring – e.g. requiring those who have trainees to be competent mentors;
  • Insufficient management training that impacts the current and future training environment – e.g. requiring that postdoctoral training including both management and mentoring training required to competently manage a research group; ensuring that faculty also have such training that is refreshed periodically, including an introductory mandatory management training course in their first semester on the job; and only awarding funds to institutions that have such programs in place. Such requirements exist for treatment of animals, and all stakeholders should ensure that treatment of employees is similarly held to a certain standard. Likewise training on implicit and unconscious bias, particularly immediately before hiring or peer review activities, and sexual harassment training should be in place, similar to training for misconduct in research requirements.”

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