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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 ~ 77
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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 178
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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 179
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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 .~80
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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: