Female Science Professor has two interesting posts up yesterday and today concerning allocating investigator effort and other costs to Federal research grants. Her basic gripe is that university and granting agency officials are forcing her to lie and/or pretend that she can accurately measure actual percent effort on a specific Federally funded project and can promise that software licenses (or equipment) charged 100% to a particular award can never be used for any purpose other than the direct furtherance of the specific aims of that award.
In relation to allocation of effort, she relates a discussion with a university grant management official about her percent effort on a particular project as follows:

And so on. We did not reach a number. I pleaded with her to tell me what number would seem like a good number and she refused because we might be audited and it would be bad if I worked more than what was listed and it would be bad if I worked less than what was listed. Every time I suggested a number, she rejected it because it was either somehow not an acceptable number (too low, too high) for mysterious accounting reasons or she wasn’t convinced it was accurate. I said that if she told me a good number, I would promise to work that amount, although I was of course lying because I’m going to work whatever amount is best for the project in the time I have available, and also I still don’t get the concept of time and effort being different but the same. She refused.

In relation to allocation of the cost of a specific software license to be used to analyze experimental data, she complains:

As regular FSP readers surely know by now, some of these rules and regulations make me crazy.
Example: I found myself promising recently that I would never ever ever use a software site license that I purchased with one grant for any activity not related to that specific grant.

The university and/or governmental officials who are putting FSP in the position of thinking she needs to lie and/or pretend about allocation of effort and other costs to Federally funded research grant awards are ignorant of the Government’s interpretation of the relevant statutes and regulations that governs allocation of costs. The relevant guidance is provided by Office of Management and Budget Circular A-21, which provides in pertinent part:

If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then, notwithstanding subsection b, the costs may be allocated or transferred to benefited projects on any reasonable basis, consistent with subsections d.(1) and (2).

This provision explicitly treats the situation where investigator effort or other cost benefits more than one project, but where the relative proportion of the benefit of the cost to the multiple projects cannot be explicitly determined. In this situation, the effort or cost may be allocated on any reasonable basis.
In the case of effort allocation, it would thus be perfectly acceptable for a PI to allocate her effort equally among her multiple grant awards, or to allocate her effort in proportion to the size of each of those grant awards, or in proportion to the number of other personnel being suppported by each of those grant awards. It would even be reasonable for the PI to simply make an estimate on no explicit basis of the effort devoted to each grant.
As a practical matter, the only way a PI’s allocation of effort is going to cause a problem in an audit is when the allocation is absurd on its face. For example, obviously you cannot devote more than 100% effort total to all of your professional activities. And if you are a teaching faculty, you also cannot allocate 100% of your effort to sponsored research.
More subtle cases would be like a Provost allocating 90% of her effort to sponsored grants. It is is simply not feasible that it only takes 10% effort to be a Provost.
In the case of other cost allocation, if you purchased a software license (or piece of equipment) with the purpose at the time of purchase to use that license for pursuing the aims of the grant that the license was charged to, and that you later figure out that the software can be used for some other purpose in your lab related to other projects or activities, that is absolutely fine, so long as the allocation of 100% of the cost of the license to that grant was “reasonable” at the time it was charged. If you purchased the license to perform necessary analysis of data relating to the charged grant, and you then performed all of that analysis, then it was totally reasonable to charge 100% of that license to that grant, regardless of what you do with the software above and beyond that analysis.
University or Federal agency officials who demand an explicit quantitative basis for allocation of effort and/or costs in situations where the interrelated nature of scientific research projects in a laboratory make such an explicit computation impossible are failing to follow the guidance of OMB Circular A-21.

The blog “Tales of the Genomic Repairman” is authored by:

A semi-cultured, good-natured graduate student in biomedical sciences who escaped out of the deep south.

Sounds intriguing, let’s sample.

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I thought Abel Pharmboy was exaggerating when he retweeted a Twitt from Tom Levenson as “Pulitzer bait”. Christ. Just go read this two part series at the Colorado Springs Gazette.
The hell of war comes home.

Before the murders started, Anthony Marquez’s mom dialed his sergeant at Fort Carson to warn that her son was poised to kill.
It was February 2006, and the 21-year-old soldier had not been the same since being wounded and coming home from Iraq eight months before. He had violent outbursts and thrashing nightmares. He was devouring pain pills and drinking too much. He always packed a gun.
“It was a dangerous combination. I told them he was a walking time bomb,” said his mother, Teresa Hernandez.
His sergeant told her there was nothing he could do. Then, she said, he started taunting her son, saying things like, “Your mommy called. She says you are going crazy.”

Warning signs.

Needham’s father and Andrew Pogany , a veterans’ advocate and former Fort Carson sergeant, persuaded commanders to keep Needham from going back to Iraq so he could continue psychiatric treatment.
But, his father said, his son didn’t get it.
Laws prevent the Army from discussing medical treatment of soldiers. Needham’s father said his son was kept on the drugs but never received counseling.
Instead, he said, his son was berated by sergeants.
“They would write things on the chalkboard in his barracks like ‘John Needham is a shit bag cry baby PTSD boohoo,'” his father said.

Today DoucheMonkey and Comrade PhysioProf received the following letter from a reader:

Drug Monkey and Physioprof:
I follow your blog quite a bit. I am writing with the hopes that you can publicize something that has happened to me and others that I find ethically egregious and could happen to other NIH-funded scientists. I will give you the short story, but if you want all the sordid details, I can share them with you.
I am an assistant professor (about 3 years into starting my lab) at a research university. On Monday of this week, I received an email from a freedom of information act specialist saying that a secretary at another research university had requested a copy of my recently funded R01 and that I had 5 days to comply. I called the secretary (who was requesting for an anonymous physician) and explained to her that there was a ton of unpublished data and a research plan for the lab that I thought when writing was confidential. I then offered to send her the grant in its entirety without government involvement if she would have the physician send me an email promising to keep it confidential. I should point out that I am very good about sharing reagents and have given out my grants (funded R01, R21, R03 and foundation grants) to others with the agreement that they stay confidential. Two days after my phone call (and subsequent email), this secretary sent a very curt email saying that they “preferred to go through the freedom of information act.”
At this point, I got nervous. I called the FOIA specialist and found out that I could redact portions of my grant but my PO would have to approve the redactions. I found out that this mechanism for obtaining grants is typically used by animal rights activists and labor unions (trying to unionize technicians), but is incredibly rare for competitors to try to do this. In asking, none of the senior faculty in my department or at the research institution where I did my post-doc had ever had this happen to them. I also found out from the FOIA specialist that 2 other grants from other investigators had been requested. One awarded to an investigator at another research university had come while he was out of town, and the NIH sent it out in its entirety. In his email correspondence to me, this investigator was very upset and was receiving little support from his school. He wrote that the only thing he knew to do was to spend the summer writing half-finished papers.
After receiving his email, I contacted my Dean. He has been incredibly supportive and the school has found a pitbull of a lawyer for me in their general counsel’s office. We are fighting this vigorously, and beyond the Dean, higher level officials at the school are also involved.
While this request may be technically legal, it is certainly unethical and terribly noncollegial. I still don’t know who the anonymous physician is. Imagine being forced to share your unpublished data and research plan with an anonymous colleague when you wrote the grant with the understanding it would stay confidential!
I would very much like you guys to highlight this situation on your blog to let others know (a) this can be done and (b) this can be fought.

Sounds about right…

via YFS, via 49 percent

Apparently Rep Issa (R; CA) has been successful in getting his amendment to prevent the NIH from funding three research projects through the House of Reps (or was it just committee?). We’ll have to follow this to see how it goes. The grants are apparently:

(Ed note: RePORTER FAIL! can’t figure out how to direct link projects..I’ll work on it. Update: CRISP to the partial rescue)
Great isn’t it? There you are, fighting to get your project funded, surmounting the usual procedural hurdles in the grant process. Finally, you get the grant funded and can get down to the business for which you are employed- doing good science in the interests of national, nay worldwide, public health. And some politician wants to prevent further funding of your project in the middle of the award period for naked political posturing purposes. Grand.
This is not new. Remember Rep Toomey?

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A new paper in the print queue at Drug and Alcohol Dependence presents a review of MDMA-related fatalities in Australia across a five year interval. It makes a good addition to the sort of Case by Case Report stuff that I usually talk about.

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