Research Opportunities for New and “At-Risk” Investigators to Promote Workforce Diversity

June 10, 2022

NIDA, NIMH, and NINDS have issued a Program Announcement (PAR-22-181) to provide Research Opportunities for New and “At-Risk” Investigators with the intent to Promote Workforce Diversity.

This is issued as a PAR, which is presumably to allow Special Emphasis Panels to be convened. It is not a PAS, however, the announcement includes set-aside funding language familiar to PAS and RFA Funding Opportunity Announcements (FOA).

Funds Available and Anticipated Number of Awards The following NIH components intend to commit the following amounts for the duration of this PAR: NINDS intends to commit up to $10 million per fiscal year, approximately 25 awards, dependent on award amounts; NIDA intends to commit up to $5 million per fiscal year, 12-15 awards, dependent on award amounts; NIMH intends to commit up to $5 million per fiscal year, 12-15 awards, dependent on award amounts; Future year amounts will depend on annual appropriations.

This is a PA typical 3 year FOA which expires June 7, 2025. Reciept dates are one month ahead of standard, i.e., Sept (new R01) / Oct (Resub, Rev, Renew); Jan/Feb; May/Jun for the respective Cycles.

Eligibility is in the standard categories of concern including A) Underrepresented Racial/Ethnic groups, B) Disability, C) economic disadvantage and D) women. Topics of proposal have to be within the usual scope of the participating ICs. Eligibility of PIs is for the familiar New Investigators (“has not competed successfully for substantial, NIH (sic) independent funding from NIH“) and a relatively new “at risk” category.

At risk is defined as “has had prior support as a Principal Investigator on a substantial independent research award and, unless successful in securing a substantial research grant award in the current fiscal year, will have no substantial research grant funding in the following fiscal year.

So. We have an offset deadline (at least for new proposals), set aside funds, SEPs for review and inclusion of NI (instead of merely ESI) and the potential for the more experienced investigator who is out of funding to get help as well. Pretty good! Thumbs up. Can’t wait to see other ICs jump on board this one.

To answer your first question, no, I have no idea how this differs from the NINDS/NIDA/NIAAA NOSI debacle. As a reminder:

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 “debacle” part is that right after NIDA and NIAAA joined NINDS in this NOSI, the Office of the Director put it about that no more ICs could join in and forced a rescinding of the NOSI on October 25, 2021 while claiming that their standard issue statement on diversity accomplished the same goals.

I see nothing in this new PAR that addresses either of the two real reasons that may have prompted the Office of the Director to rescind the original NOSI. The first and most likely reason is NIH’s fear of right wing, anti-affirmative action, pro-white supremacy forces in Congress attacking them. The second reason would be people in high places* in the NIH that are themselves right wing, anti-affirmative action and pro-white supremacy. If anything, the NOSI was much less triggering since it came with no specific plans of action or guarantees of funding. The PAR, with the notification of intended awards, is much more specific and would seemingly be even more offensive to right wingers.

I do have two concerns with this approach, as much as I like the idea.

First, URM-only opportunities have a tendency to put minority applicants in competition with each other. Conceptually, suppose there is an excellent URM qualified proposal that gets really high priority scores from study section and presume it would have also done so in an open, representation-blind study section. This one now displaces another URM proposal in the special call and *fails to displace* a lesser proposal from (statistically probable) a majoritarian PI. That’s less good than fixing the bias in the first place so that all open competitions are actually open and fair. I mentioned this before:

These special FOA have the tendency to put all the URM in competition with each other. This is true whether they would be competitive against the biased review of the regular FOA or, more subtly, whether they would be competitive for funding in a regular FOA review that had been made bias-free(r). […] The extreme example here is the highly competitive K99 application from a URM postdoc. If it goes in to the regular competition, it is so good that it wins an award and displaces, statistically, a less-meritorious one that happens to have a white PI. If it goes in to the MOSAIC competition, it also gets selected, but in this case by displacing a less-meritorious one that happens to have a URM PI. Guaranteed.

The second concern is one I’ve also described before.

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.

So, while this PAR is a great tactical act, we must be very vigilant for the strategic, long term concerns. It seems to me very unlikely that there will be enthusiasm for enshrining this approach for decades (forever?) like the ESI breaks on merit scores/percentiles/paylines. And this approach means it will not be applied by default to all qualifying applications, as is the case for ESI.

Then we get to the Oppression Olympics, an unfortunate pitting of the crabs in the barrel against each other. The A-D categories of under-representation and diversity span quite a range of PIs. People in each category, or those who are concerned about specific categories, are going to have different views on who should be prioritized. As you are well aware, Dear Reader, my primary concern is with the Ginther gap. As you are aware, the “antis” and some pro-diversity types are very concerned to establish that a specific person who identifies as African-American has been discriminated against and is vewwwwy angweee to see any help being extended to anyone of apparent socio-economic privileges who just so happens to be Black. Such as the Obama daughters. None of us are clean on this. Take Category C. I have relatively recently realized that I qualify under Category C since I tick three of the elements, only two are required. I do not think that there is any possible way that my qualification on these three items affects my grant success in the least. To do so would require a lot of supposing and handwaving. I don’t personally think that anyone like me who qualifies technically under Category C really should be prioritized against, say, the demonstrated issue with the Ginther gap. These are but examples of the sort of “who is most disadvantaged and therefore most deserving” disagreement that I think may be a problem for this approach.

Why? Because reviewers will know that this is the FOA they are reviewing under. Opinions on the relative representation of categories A-D, Oppression Olympics and the pernicious stanning of “two-fers” will be front and present. Probably explicit in some reviews. And I think this is a problem in the broader goals of improving equity of opportunity and in playing for robust retention of individuals in the NIH funded research game.

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*This is going to have really ugly implications for the prior head of the NIH, Francis Collins, if the PAR is not rescinded from the top and the only obvious difference here is his departure from NIH.

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