NINDS Issues NOSI Requesting Applications from URM Investigators

Notice NOT-NS-21-049 Notice of Special Interest (NOSI): NIH Research Project Grant (R01) Applications from Individuals from Diverse Backgrounds, Including Under-Represented Minorities was released on May 3, 2021.

The NOSI is the new Program Announcement, for those who haven’t been keeping track. As with the old PA the direct benefit is not obvious. There is no set aside funding or promise to fund any applications at all. In the context of Ginther et al 2011, Hoppe et al 2019, the discussions of 2020 and the overall change in tone from the NIH on diversity matters, it is pretty obvious that this is designed merely to be the excuse. This PA, sorry NOSI, is what will permit Program to pick up grants on the (partial?) basis of the PI’s identity.

What identities? Well the NOSI re-states the categories A, B and C that are familiar from other similar documents.

A. Individuals from racial and ethnic groups that have been shown by the National Science Foundation to be underrepresented in health-related sciences on a national basis…

B. Individuals with disabilities, who are defined as those with a physical or mental impairment that substantially limits one or more major life activities

C. Individuals from disadvantaged backgrounds, defined as those who meet two or more of the following criteria…

And then there is a statement about gender intersectionality to close out.

GREAT! Right?

Yeah, it is. To the extent this is used to figure out a way to start working the naked, quota based, top down, heavy handed affirmative action that has been benefiting ESI applicants since 2007 on the NIH funding disparity identified in Ginther and Hoppe, this is a win. From the very start of hearing about Ginther I‘ve been talking about exception pay rapid solutions and this only heated up with the disingenuous claim that exception pay was not accelerating the disparity which was made in Hoppe et al. The NOSI allows pickups/exception pay, for sure, under the “special interest” idea. I don’t know if this will end up generating explicit payline benefits on a universal categorical basis as has been done at many ICs for ESI applications. The difference, of course, is that the former is much more variable and subject to biases that are expressed by Program Officers individually and collectively. Explicit rules would be better…..ish. It’s complicated.

In a news piece by Jocelyn Kaiser, the prior NIH Director Elias Zerhouni was quoted saying that study sections responded to his 2006/2007 ESI push by “punishing the young investigators with bad scores”. As I have tried to explain numerous times, phrasing this as a matter of malign intent on the part of study section members is a mistake. While it may be true that many reviewers opposed the idea that ESI applicants should get special breaks, adjusting scores to keep the ESI application at the same chances as before Zerhouni’s policies took effect is just a special case of a more general phenomenon.

NIH grant reviewers have a pronounced tendency to review grant proposals with an eye to “fund it” versus “don’t fund it”. Continual exhortations from SROs that panels do not make funding decisions, that they should review merit on a mostly continuous scale and that they should spread scores has minimal impact on this. Reviewers have a general idea of what scores will result in funding and what will not and they score accordingly*. I have mentioned that when I first started on study section the SRO would actually send us score distributions as part of the effort to get us to spread scores. INVEVITABLY the scores would stack up around the perceived funding line. Across a couple of years one could even see this move in tandem (with a round or two lag, obv) with what was funding at the 2-3 ICs that most grants were assigned to.

One interpretation of the “punishing” phenomenon is simply that panels were doing what they always do (as I assert anyway) in matching scoring to their perception of the payline and their gut feeling about whether a given app was deserving. What this assumes, of course, is that whatever biases were keeping the applications of the ESI-qualifying individuals from getting good scores in the past were still present and the reviewers were simply continuing the same behavior.

My concern with the new NOSI is, of course, that something similar will happen with the applications that qualify for this NOSI. There is the potential for a growing general suspicion (assumption? bias?) among study section reviewers that “oh, those URM PIs get special breaks” and then the scores will get even worse than they were before this idea started to percolate around the culture. It might be accelerated if the ICs generate explicit statements of relaxed paylines…but the campfire chatter about how the NOSI is being used will be sufficient.

Vigilance!

Vigilance is the thing. NIH cannot be permitted to put this in place, pay no attention to the results and “suddenly realize” five or ten years later that things are not working according to design.

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*generally. Reviewers can be mistaken about paylines. They can be miscalibrated about scores and percentiles. They have a limited picture which only reflects their own knowledge of what is being funded. But still, there is an aggregate effect.