graduate education, and this may be their greatest contribution to the biomedical research training environment.

Thus, the many requirements and expectations for support activities centered on training grants, such as minority recruiting, education in the responsible conduct of research (RCR), and professional development, have improved the overall tenor of graduate education immensely over the past decade. These expectations have come at a considerable price, however, and this price has largely been covered by institutional funds. The current 8 percent indirect cost allowance (which is not applied to tuition and fees, health insurance, and expenditures for equipment) is insufficient to cover the university’s costs. Similarly, the K awards, which have served a tremendously important role is fostering the early career development of both basic and clinical biomedical researchers, use the same facilities as funded researchers and generate their own significant administrative costs, yet they have the same 8 percent indirect cost allowance, which as best one can determine is arbitrary and is based on no carefully argued rationale.

The indirect cost rate has varied over time. Prior to 1958, the rate for training grants was set at 8 percent by the Department of Health, Education and Welfare, and the rate has remained at this level to this day. The rate on non-training grants was increased to 15 percent in 1958 and to 20 percent in 1963. In 1966 the ceiling on indirect costs was removed, but in 1991 OMB Circular A-21 imposed a cap of 26 percent on the recovery of administrative costs from research grants, and the cap has remained unchanged in spite of compelling documentation by the Council on Governmental Relations that these costs in all the top research universities sampled were significantly greater than could be recovered under the 26 percent cap. As a result, many of the improvements in graduate education and early career development, such as special skills courses, increased focus on interdisciplinary studies, increased diversity, RCR training, and career advising and outcomes research, have all come through resources provided by the institutions applying for NRSA support.

The committee finds that the institutional commitment of resources for training grants and K awards is no different from that for research grants. Graduate and postdoctoral trainees require the same facilities in the laboratory as their counterparts in the same laboratory who are supported on a research grant that carries the institution’s negotiated rate. Likewise, individuals on K awards act in a capacity similar to that of a researcher on an R01 or other research project grant. The committee was not unanimous with regard to the NRSA part of the following recommendation because of concerns about costs and the reduction in program size that could result from a stagnant NIH budget, but it did endorse the increase for the K awards.


Recommendation 2–2: NIH should consider an increase in the indirect cost rate on NRSA training grants and K awards from 8 percent to the negotiated rate currently applied to research grants. The increase in the rate could be phased in over time, for example, by increasing the rate by 8 percent each year until the negotiated rate is reached.


Implementing this recommendation would require a five- or six-fold increase in indirect costs, or $191 million for the NRSA program at its current size and $338 million for K awards. An increase of $529 million is significant, even in light of the reasoning to have NIH share the full cost of administrating these programs, but the committee wanted to record its support for the measure and its hope that it could be implemented at some point.

RESPONSIBLE CONDUCT OF RESEARCH

NIH’s NRSA grants require awardee institutions to establish specific curricula in the responsible conduct of research. Indeed, in late 2009 NIH issued a detailed policy statement outlining its expectations along with recommendations on how to approach these expectations (NIH policy statement NOT-OD-10-019). It is worth noting that National Science Foundation (NSF) has issued similar requirements for all personnel participating in NSF-funded research, including undergraduate students.

The requirement of RCR training within the T32 mechanism has led to the development of curricula and educational practices for NRSA that would benefit all students and postdoctorates being trained in biomedical and health sciences research and should be required in all graduate and postdoctoral education programs supported by the NIH. Since with relatively few exceptions the majority of this training takes place in laboratories supported by NIH research program grant (RPG) mechanisms, this leads to the expectation that all students supported by the NIH (i.e., including those students supported by R01 grants during their education) should be required to benefit from such training.


Recommendation 2–3: All graduate students and postdoctoral fellows who are supported by the NIH on RPGs should be required to incorporate certain additional “training-grant-like” components into their regular academic training program. These should include RCR training, exposure to quantitative biology, and career guidance and advising.

NIH DIVERSITY INITIATIVES WITHIN THE NRSA PROGRAM

Minorities1 now account for 50 percent or more of the population in several states, and at some time within

1

Minorities are defined as Blacks, Hispanics of Puerto Rican , Cuban, or Mexican extraction, American Indians, and Pacific Islanders. Does not include Asian.



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