New Steps to Help Ensure Safe Work Environments for NIH-Supported Research

If an institution requests approval to remove a principal investigator (PI) or other senior key person named in the grant award due to concerns about safety and/or the work environments (e.g. due to concerns about harassment, bullying, retaliation, or hostile working conditions), NIH expects to be notified. If an institution requests a change of recipient institution, and there are concerns about safety and/or work environment involving the PD/PI, NIH expects to be informed.

The reason is clear — NIH does not tolerate sexual harassment. Period. The two situations we cited above are two critical loopholes identified by the Advisory Committee to the NIH Director’s (ACD) Working Group on Changing the Culture to End Sexual Harassment as needing more attention.

We are moving to close those gaps in our continued effort to address sexual harassment across NIH-funded research. Today, NIH has issued new guidance to grantees setting clear expectations that for awards (competing, non-competing and supplements) issued after today, NIH expects recipients requesting prior approval for changes in PI, key personnel, or recipient institution, to include mention as to whether these requests are related to concerns about the safety and/or work environment, including issues related to sexual harassment or bullying. (See NOT-OD-20-124).

 As of tomorrow, when requesting changes in either investigators (see NIH GPS Section 8.1.2.6) or movement of a grant to a new recipient institution (see NIH GPS Section 8.1.2.7) grantees are expected to mention if there are related concerns about the safety and/or work environments.

The new guidance marks critical progress in NIH’s efforts to foster a culture of safety and respect for all those working in science and sends a clear message that sexual harassment and other inappropriate behaviors are unacceptable and will not be tolerated.

We describe these steps in an editorial published today in Science. The new guidance builds upon previous steps NIH has taken to strengthen reporting sexual harassment and other professional misconduct taking place at grantee institutions in the context of NIH-funded research.

Our Anti-Sexual Harassment: for NIH Awardee Organizations and Those Who Work There website outlines NIH expectations, policies and requirements, and helps those concerned about sexual harassment at their institution find help. Among the resources on the site are a webform that allows for anonymous notification of concerns to NIH that sexual harassment is affecting an NIH-funded project.

While these first steps are critical, we recognize that we have a number of recommendations left to tackle to fulfill the ACD’s vision of a research culture free from sexual harassment. But our commitment remains strong, and we will get there. This is not just important for women in science. It is important for science. 

This blog was co-authored by Dr. Mike Lauer, the NIH Deputy Director for Extramural Research (OER).  Dr. Lauer writes about NIH research funding policies and data at his blog, Open Mike.

Posted by Dr. Carrie D. Wolinetz, June 11, 2020

Dr. Mike Lauer
NIH Deputy Director for Extramural Research

Summary of “NIH Workshop on Optimizing Reproducibility in Nonhuman Primate Research Studies by Enhancing Rigor and Transparency” Now Available

First, I want to take a moment to wish you all well as we collectively weather the unprecedented novel coronavirus pandemic. I hope all readers of this blog, and their loved ones and friends are staying safe and well. As you might imagine, COVID-19 response is occupying a great deal of the bandwidth of NIH right now, as we ensure the safety of our workforce and accelerate scientific solutions to the current crisis. However, even from remote workspaces and amidst the flurry of pandemic response, work to support the ongoing mission of the agency is continuing…

Today, NIH is posting a summary of a workshop held in February which brought together key stakeholders to explore the intersection of optimizing research rigor and research involving non-human primates (NHP). You may recall I blogged about this last fall, and I noted the continuity with other NIH efforts assessing the landscape of NHP research, as well as the agency’s ongoing initiative to enhance research reproducibility through improvements in rigor and transparency. In the interim, a neuroethics working group of the Advisory Committee to the NIH Director (ACD) produced a report in October 2019 “Enabling and Enhancing Neuroscience Advances for Society” which included ethical considerations for NHP research, particularly relative to emerging biotechnologies. Collectively, these presented a terrific backdrop to bring together experts in various scientific disciplines, primatologists, veterinarians, and bioethicists, including representatives from National Primate Research Centers, academic institutions, government, industry and non-profit groups for two days of in-depth discussion.

A number of common themes emerged, including:

  • Ethical considerations should extend beyond legal and regulatory requirements.
  • It is of critical importance to understand the course of human disease and to understand the strengths and limitations of the animal model proposed for use.
  • Rigor and transparency necessitates data sharing yet there are challenges.
  • Rigor, welfare, husbandry, environment, and behavior are all interrelated.
  • Rigorous and reproducible science is part of a virtuous learning cycle.

However, this concise summary gives short shrift to the rich and thoughtful discussion of the unique opportunities and challenges shared by the NHP research community, and I encourage you to read the full report to get a better sense of the full breath of issues discussed. As one participant noted, even the lunchtime conversations represented exciting exchanges of ideas at the nexus of scientific and clinical opportunities, ethical considerations, ensuring rigor and transparency, and the nuances of animal welfare and husbandry. It highlighted how interdisciplinary engagement – from experts in primatology, statisticians, experimental design, clinicians, ethicists, data scientists, and basic biologists – can be incredibly useful to maximize the knowledge generated by working with these critically important animal models. In addition, it became very clear that lessons learned from NHP can more broadly benefit enhancing rigorous study design in all animal research and that data sharing is key for facilitating rigor and reproducibility.

While the discussion itself was important in fostering those connections, a natural question to ask is: what happens next? The proceedings of the workshop feed into the broader efforts of the ACD Working Group on Enhancing Reproducibility and Rigor in Animal Research (of which I am a member) in its deliberations. This group has been charged with assessing and making recommendations to enhance the reproducibility and rigor of animal research by improving experimental design, optimizing translational validity, enhancing training, and increasing the transparency of research studies involving animal models, and is expected to present an interim report to the ACD in June.

‘Twas the Night Before……

‘Twas the night before Christmas, And nobody’s here.

All of us Feds are on break, But please don’t you fear…

The policy gurus, soon will return,

NIH’s midnight oil will not cease to burn.

The NExTRAC working groups are now on their way,

Emerging biotech we need to think on today.

And the Draft Data Policy is finally out,

Waiting for comments, the cheers and the shouts.

The BESH researchers are nestled, snug in their delay,

As we work with them on ensuring results see light of day.

Rumors are flying on the public access front,

We have no comment, if I may be so blunt.

The Common Rule at long last will go into effect,

Genomic Summary Results, you can now freely detect.

Return of results, we’re still thinking deep thoughts,

How to respect research participants, who we care about lots.

We’re thinking about ethics for humans, monkeys, and BRAIN,

That doesn’t mean new policy, is our constant refrain!

And I, in my role as NIH Chief of Staff,

“What work-life balance?”, I’ve been known to laugh.

On sexual harassment, let me be very clear,

Unacceptable, immoral, and not welcome here.

The culture that allows bad behavior to occur,

Is something everyone of us is responsible for.

Science needs to change, NIH needs to drive it,

We must unite with those who have somehow survived it.

“So, on civility, on respect, on diversity and inclusion!

On safe research spaces, down with biased exclusion!

On polices that promote only science that is best,

Rigorous and translatable, when put to the test!”

And when the NSABB convenes in the first quarter of ’20,

Biosecurity and transparency, we’ll talk about plenty!

The NIH Guidelines need a refresh,

And improving clinical trials goes well beyond BESH.

Heritable gene editing is still all the rage,

Will the world’s governance bodies get on the same page?

Policy opportunities abound in the coming New Year!

From all of our stakeholders, we’re dying to hear…

But for now let’s pause, as we rarely do,

To say from NIH OSP, happy holidays to you!

A Quick Word About Human Embryo Model Systems

Rapidly emerging areas of science can pose interesting challenges for policy frameworks intended to provide oversight of biomedical research or statutory limitations on NIH funding. A recent example, as described in this story on NPR, is an area of research in which scientists are hoping to gain insight on human development by creating structures that model certain aspects of embryonic development. The methods used to create these various model systems generally use human pluripotent stem cells, which are then differentiated into cell types with characteristics and/or organization similar to those seen in human embryos.

NIH has had a long-standing statutory limitation on funding research involving human embryos. The limitation, sometimes called the ‘Dickey-Wicker” amendment, is included annually in HHS appropriations language and has been incorporated into the NIH Grants Policy Statement (GPS). The GPS specifies that “NIH funds may not be used for (1) the creation of a human embryo or embryos for research purposes…”

You can probably anticipate the question I usually have to address. Can research involving various models of aspects of human embryo development be supported by NIH? The answer is “it depends.”

As a steward of taxpayer funds, NIH considers, on a case-by-case basis, whether we can support specific research proposals given the limitations set by the NIH GPS. NIH applies the same considerations to both research proposing the use of human embryos and research that aims to create or use experimental systems with human cells that model human embryos. We examine all experimental details specific to that experiment in order to make an informed decision about whether the research could be supported.

It is also important to note that even if NIH were to determine that proposed research is supportable under the limitation–NIH Institutes and Centers consider scientific merit, program priorities, their portfolio balance, and the availability of funds in making final funding decisions.

To help identify and better understand some of the unknowns associated with this nascent field of research, the National Academies of Science, Engineering, and Medicine will be holding a state of the science workshop on mammalian embryo model systems on Friday, January 17, 2020. I am looking forward to hearing more from the experts in the field about the opportunities and challenges that face this type of research.

Related Blog Post: Sharing Our Current Thinking: Models Containing Aspects of Human Embryos

Posted by Dr. Carrie D. Wolinetz, October 10, 2019