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9. ADMINISTRATION OF THE NRSA PROGRAM
The highest priorities set by the Corrun~tte. during the past
two years have been to assess overall needs and Brake
specific reconunendations concerning levels and mechanisms of
support and areas of training requiring special attention.
In its ~ 975 and ~ 976 reports the Committee has not addressed
i ssues that would require changes in the legislation or,
with the exception of announcement fields, in the general
administration of the program by the funding agencies. With
the maturation of the program, however, the Committee
believes it now is appropriate e to address some of these
issues and to make several specific recommendaticns, since
funding agencies, individuals, and the academic institutions
have now had sufficient experience with it.
The committee notes the complex situation that
confronted the agencies in FY ~ 975 in beginning to
administer the new program. With the passage of the MESA
legislation, it became necessary for agencies to meet their
commitments to individuals and institutions who had received
awards in previous years under a different training
authors ty and two separate sets of policies and guidelines,
while simultaneous y developing policies and procedures for
implementing a third NFSA program of f ellowships and
training grants. The number of commitments made under the
former training authorities are decreasing rapidly, and all
wall terminate in FY 1979. With the NESA program now the
predominant mechanism for the support of research training,
and recognizing that this is the third year in which awards
have been made, the Committee offers in the following
sections specific recommendations about some general policy
issues not addressed to date.
GENE~L POLICY ISSUES AND RECOMMENDATIONS
Three-Year Limitation on Awards
and criteria for Waiver of Limitation
The MESA Act states that ''The period of any National
Research Service Award made to any individual.~.may not
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exceed three years in the aggregate unless the Secretary for
good cause shown waives the apple ication of the ~hree-year
~ imit to such individual. " The Act thus pi aces a three-
year ~ ~ mit on the time any individual may hold an award and
permits the Secretary for good cause to waive that three-
year limit.
It is first necessary to ~ nterpret whether the three-
year lime tation applies to all awards made in the lif etime
of the individua ~ or whether it permits a three-year award
at the predoctoral ~ evel and a three-year award at the
postdoctoral ~ ever . The Committee believes that the latter
in' erpr=-ation is a reasonable reading of Ohm statute, is
cons istent with its purpose, and ~ s not contrary to its
legis Cat ire history.
The Committee notes ~ hat many individuals at the
they begs n predoctoral training are unable to pro ject
clearl y their pi ens for a total research training program,
particularly as this concern s their future interest in,
duration of, and need for federal support during
postdoctoral training. The result of this is that some
individual s may embark upon a program of predoctoral
training up ilizing NRSA support without having any clear
knowledge of how this util ization of federal support at the
predoctoral Beret may af feet their application for further
NRSA support, which may be required for a period of
postdoctoral training. Others may forego any f ederal
support during predoctoral training for fear that this will
jeopardize federal support for postdoctoral training at a
ater date. This is of particular importance to graduate
students in the basic biomedical sciences, for example,
where more than 6 0 percent go on for postdoctora ~ training.
The Commi ~ tee believes the' a maximum of MESA support
for three years each at the predcctoral and postdoctoral
.7ev~Is for any one individual would provide sufficient
flexibility to accommodate the needs of applicants, meet the
objectives of the NRSA program, and be consistent with the
spirit of the legislation. If this is not achieved by
interpretation of the statute, it should be achieved through
publication of criteria a implementing ~ he waiver provisions
of the law.
The avai lab] e data show that, in contrast to
nonminorities, minori'i es get their degrees at a later age,
generally need more financial support, and frequently
demonstrate a need for additional formal training to remedy
deft cienc ies ~ n background preparation. The Committee
therefore believes that special support provi signs are
necessary (see recommendation in the section "M~r~orities, "
Chapter 8~.
With regard to the provi sion of the Act that permits the
S e or eta ry to wa iv e the three- yea r limi tati on o n award s, and
regardless of the decision concerning interpretation of the
three-year limit, it is necessary to develop criteria by
which requests f or waiver can be consi dered. The PHS in May
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~ 975 issued regulations (Appendix K1} that stated that for
the purpose of determining what constitutes "good cause, "
"the Secretary shall take into account such fact ors as
whether the apple icant proposes to complete both Fredoctoral
and postdoctoral training programs under the Award or
whether the applicant proposes to pursue a combined program
leading to the degrees of doctor of medicine and doctor of
philosophy."
Although these regulations do ref er generally to some of
the relevant factors that the Secretary may take into
account in determining waiver of the three-year limitation,
the Committee believes that a specific set of criteria
should be level oped and announced in order that al ~
potential applicants for support under the NRSA Program may
hay" complete understanding of the specific f actors that
will enter into the determination of requests f or waiver.
The Committee understands from its discussions with agency
o f f ic ia Is th at a ma j o ri ty of the Aqua s t s f or waiver can be
expected to be suffice entry well- justified as to result in
favorab, e decisions. Nonetheless the committee believes
th at it would be in ~ he be st inte re sts o f the program i f
cat ear criteria were established to determine these matters.
Recommendation. It is recommended that, as soon as
possible, the agencies determine the proper interpretation
of the three-year limitation in the UREA Act and establish
the specific criteria by which requests for waiver of the
three-year limitation will be determined. Applicants whose
requests for waiver are al sallowed should receive in writing
the spe ci fi c rea sons f 0 r thi s de c i s ion, and an appropriate
procedure should be established whereby an adverse finding
may be appea led.
Payba ck P rovi s i ons and Wa iver
of Payback Requirement
Public Law 93-34 ~ categorizes both the kinds and extent of
service acceptab, e as payback by NRSA recipients in lieu of
monetary reimbursement and provides opportunity for the
Secretary, upon request, to authorize other types of service
activity as acceptable. The secretary may extend the period
for undertaking service provided for payback, permit breaks
in service, or extend the period for repayments..
The Committee recognizes the complexities that the
agency es face as they implement this part of the Act. It
wild review carefully and with great interest the
regulations that are proposed with regard to the conditions
and terms of service that will constitute acceptable payback
by reck pients of these awards. It is of the utmost
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importance to the success of the overall program that the
procedures and policies that are established ~ ~ ~ be
equitable, (2) be administered in a uniform manner within
and between funding agencies, and ~3) allow for all
appropriate types of service that resea~ch-trained personnel
in these fields may be expected to undertake in utilizing
their special ized training in research (see particularly the
di sc us s ~ on and recommendation in "Modi f i cation o f the
Payback Provision" in the health services research section
of Chapter 6 3 .
Recommendation. The Committee recommends that
regular ions be promulgated immediately concerning the
spe c i f i c crit eri a to be appli ed in determining wa iver of
payback requirements and that particu~ ar note be taken of
~ he special needs of specific classes of NRSA recipients.
An example e of the latter is provided by women who become
pregnant and must interrupt or terminate their training
program.
Stipend Levels
The Committee has learned that the Internal Revenue service
(IRS 3 phi s year noti f fed the PHS of an opinion that stipends
rece ived under the authority of the NRSA Act are considered
to be taxab' e. The Committee views with great concern the
practice' consequences of this development, because it may
serve as a disincentive for applicants to pursue research
training under NRSA support, and believes that the IRS
shout ~ withdraw this opinion. The Committee believes that
it is unsound publ ic pod icy for the government to grant a
research stipend and then withdraw part of it through
taxation. This amounts to a reduction in the amount of the
stipend. The Committee believes that research stipends must
be kept s Of f i ciently high to Fennit awardee s to spend f ul
time on thei r re sear ch training programs .
Above an ~ beyond the IRS opi nion on the t a x st atu s of
stipends, the Committee notes that stipend ~ evels have not
changed s ince they were f irst established in ~ 97 4, although
the cost of ~ iving has i ncrea se ~ si gni f icantIy dur ing this
period. The Committee is very much concerned that the
gradual but constant erosion of the value of the stipend
will severely handicap efforts to attract highly qualified
students into the biomedical and behavioral sciences by
requiring them to engage in outside employment in order to
supplement their incomes. The Committee believes that
students engaged in training for careers in biomedical and
behavioral science research should not be forced into part-
tim" study, since this is not conducive to timely completion
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of the rigorous training program in these scientif ic areas,
which is a necessary condition f or productive research
careers .
The Committee regrets that the stipend levee has not
been ad justed for cost-of-living increases since ~ 974 and
urges that a mechanism to provide for of fretting the effects
of cons' nuing inf ration be instituted. This ad justment must
be made with additiona ~ funding beyond that required by the
Committee ~ s recommended ~ evels of tray nees and fellows.
Recommendat ion . The Committee recommends that the
Department of HEW reque st the TRS to withdraw its opinion
that NRSA stipends are taxable. Regards ess of the outcome
of that request, the Committee recommends that Congress make
available the required additional funds to implement in EY
1979, or sooner if possible, a cost-of-living increase of no
less than 5 percent to all predoctoral and post doctoral
fell ows and trainees. The Committee recommends that future
legislation provide for an annual cost-of-living increase.
Multidisciplinary Training Grants
In recent years the NIH (specifically the NIGMS} has
moved almost entirely to providing support only for
multidepartm~ntal training grants rather than supporting
training grants in individual departments. The Committee
endorses multidisciplinary training in both the biomedical
and behavioral sciences, particularly at the predoctora'
level. It notes, however, that depending upon the
objectives of the proposed program, such training frequently
can be accomplished within a single academic department. In
other instances inter- or multidepartmental cooperative
arrangements are required. The committee thus emphasizes
the importance of distinguishing clearly between
multid~partmental grants and the desirability of and its
support for mu] tidisciplinary research training.
Administrative practice of the NIH, however, at times
has seemed to pa ace undue emphasis on the need for
applicants for training grants to develop multidepartmental
grants. The Committee concludes that it is therefore best
left to the scientific review bodies advisory to the NIH to
decide what departmental arrangements best meet the
ob j ective s f or any parti cula r propo sed program of re s earch
. ~
tram n'ng.
Recommendation: The Committee supports the concept of
__
mul t idi s c ip ~ i na ry pre doctora ~ tra in ing in the b iomedi c a ~ a nd
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behavioral sciences. However, it recommends that the NIH
not di s courage applications f rom individual departments but
accept for review applications for training grants from both
individual and multip~ e departments and allow the peer
review proce ss to determine whether the proposed
depa rtmenta l arrangement s are tho se the ~ c an be st meet the
ob jectives of: the particular program under consideration.
Announcement Fields
The information collected by the committee provides no basis
for the des ignaticn of narrow fields or topics as priorities
for research training, particularly at the predoctoral
Bevel. The committee therefore has concluded that there is
no basis at this time for determining under Section
472(a) (3) of the Act that any particular sub ject matter is
not appropriate for funding. Within the broad limits of the
be omedical and behavioral sciences, the announcements issued
by the NIH and ADAMHA should not be written in a way that
results in the exclusion of specific fields or sub ject
matter.
Thus, although the Institutes within the NIB might
conclude it is desirable to describe fields of predoctoral
training that are of special interest to the parti cular
Institute, it should be made explicit that such description
does- not confer any special priority advantage upon
applicants who apply f or support in those specific fields
and the t al ~ appl ice ti on s f or predoctora ~ support re gardle s s
o f f ie Ill wi l ~ be equa ~ ly c ompeti ti ve, wi th qua l i ty the
determinant of success.
Recommendation. The committee recommends that NRSA
announcements specif y that awards will be made solely on the
basi s of quality and merit and that no field or sub ject
matter that is within the broad limits of the biomedical and
behavioral sciences is excluded from consideration.
The Co~ranittee al so continues to question the validity of
the distinctions drawn by the NIH in their announcement of
training areas suitable for postdoctoral fellowships as
contrasted with postdoctoral training grants. During the
year the Committee opened discussion of this issue in
written communication to the Director, NIH. it requested
that the rationa le for such distinctions be provided in
writing to the Committee, which would provide a basis for
discussions between the Committee and agency officials. The
Committee wishes to be informed what fields are intended to
be excluded and why. Until these discussions are concluded,
the Committee has no further general recommendation to make
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with regard to announcement areas for postdoctoral training
apart from those specified in the present report for the
five broad areas.
Acquisition and Dissemination of Employment,
Utilization Information to Individual
Applicants and Academic Departments
The Committee believes it to be very important that students
contemplating research careers in the biomedical and
behavioral sciences be pro~riaea access to 'he most current
and valid data about the state of the labor market and
career opportunities. The views originally held by some
members of the panels and of the Committee concerning the
overall marketplace and extent of unemployment and
underutilization were modified as the result of reviewing
and analyzing the results of its surveys (Chapters 3 anti 4~.
Tt is neither desirable nor feasible to conduct annual
surveys of the breadth undertaken this year. Nonetheless,
the committee does believe that some brief annual or
biennial assessment of the levels and numbers of persons in
training, of the employment markets, and of the utilization
of skills by graduates is indicated, with the results then
made available promptly to interested individuals,
university departments, and other organizations concerned
with scientific manpower.
Recommendation. The Committee recommends that
employment findings from this year's surveys be brought to
the attention of academic departments, undergraduate
counselors, professional societies, and others concerned
with higher education and scientific manpower issues.
Publication in a journal having widespread distribution
would be one means of effecting rapid communication about
charges in career opportunities such as those currently
occurring in some of the basic biomedical science fields.
It is also recommended that during the coming year the
agencies and Committee discuss means whereby the needs and
utilization of research manpower can be better ascertained
regularly on an annual or biennial basis, with particular
interest directed toward obtaining overall information about
the increasing population of postdoctorals and nontenured
research staffs in academic institutions and, from recent
graduates, data on employment and utilization of skills..
183
Representative terms from entire chapter:
behavioral sciences
