In the wake of the Hoppe et al. 2019 report (which amounted to a perfect replication of the Ginther et al. 2011 finding of grant award discrimination against R01 applications with African-American PIs), likely stimulated further by the socio-political climate following the George Floyd murder in 2020, some elements within the NIH attempted to fix things. This was by way of their usual formal method, the issuance of targeted Funding Opportunity Announcements (FOAs).

To recap, NINDS issued NOT-NS-21-049 Notice of Special Interest (NOSI): NIH Research Project Grant (R01) Applications from Individuals from Diverse Backgrounds, Including Under-Represented Minorities on May 3, 2021 and it was rapidly joined by NIDA and NIAAA. No other ICs were added and ultimately the NOT was rescinded on Oct 25, 2021. This, and the additional FOA that I will be discussing lean heavily on the Notice of NIH’s Interest in Diversity (NOT-OD-20-031) issued November 22, 2019. This is either by citation of that Notice, by inclusion of the central concepts regarding the NIH’s interest in diversity within the US research enterprise, or both.

The categories of interest to the include A) URM, but also B) individuals with disabilities and C) those from disadvantaged socioeconomic backgrounds. A final category of interest (D) notes the extra disadvantage of women from any of the prior three categories. This statement makes it overwhelmingly clear that this is NIH’s interests that are the motivating factor. This is not contextualized as being about the interests of any particular PI who happens to qualify under the A-D criteria.

The explanation for why NOT-NS-21-049 was rescinded was that there was no reason for it since the NOT-OD-20-031 covered the same ground and the former was thus duplicative and confusing (see this Science Insider piece from Jocelyn Kaiser). We never did get a clear and public statement of why NINDS, NIDA and NIAAA disagreed, but it seemed to be due to the ICs’ program staff not being able to easily tell which applications were from PIs of these listed diversity categories.

A blog post from Mike Lauer and Marie Bernard attempted to explain the NIH viewpoint on Nov 3, 2021. It said “While the spirit of the NOSI was laudable, it may have led to an impression that by linking demographic characteristics to grant proposals, applications supporting scientists from underrepresented groups would be automatically prioritized for funding“. gee, dya think? and why would they be so scared to use this to address the clearly evidenced disparity in which such scientists were de-prioritized for funding? AKA prioritization of those demographic characteristics known as being white? “as a federal government agency, NIH must always consider existing federal requirements that apply to its programs, including legal considerations regarding the use of gender, race, or ethnicity to make funding decisions.” Given a host of other mechanisms including K99/R00, MIRA R35 and some F32 FOA which would appear to violate this consideration this seems kinda bogus.

NINDS, NIMH and NIDA tried again in 2022 after Francis Collins retired as NIH Director by issuing PAR-22-181 (NIDA, NIMH and NINDS Research Opportunities for New and “At-Risk” Investigators to Promote Workforce Diversity). This was ultimately joined by 8 more ICs. It was re-issued as PAS-25-190 Research Opportunities for New and “At-Risk” Investigators to Promote Workforce Diversity on Nov 8, 2024. I have seen no mention from NIH anywhere that explains why this new approach did not also run afoul of the aforementioned consideration of federal requirements. There was no change in the President nor any change in the 117th Congress. The only major difference that one can see is the departure of good ol’ aw-shucks tyrannical bully and Ginther Gap can-kicking Francis Collins as the Director of the NIH in December of 2021.

For reasons I do not entirely understand, NIAID issued their own version PAR-22-241 NIAID Research Opportunities for New and “At-Risk” Investigators to Promote Workforce Diversity on Sept 21, 2022, which was re-issued with NIDDK as PAR-23-275 NIAID and NIDDK Research Opportunities for New and “At-Risk” Investigators to Promote Workforce Diversity (posted Sep 13, 2023).

Both original FOA included a requirement to submit a letter of eligibility “explaining how participation of the identified PD/PI(s) would further the goals of the New and At-Risk Investigators to Promote Workforce Diversity Research program, consistent with the Notice of NIH’s Interest in Diversity“. This put the focus squarely on the personal characteristics of the PI. On their identity under the A-D criteria.

The PAR-23-275 included an additional requirement for a second letter “describing the PD/PI’s commitment to promoting diversity, equity, inclusion, and accessibility (DEIA)“. This may require some decoding for some Readers. I’ve written here about how this workaround is used somewhat prominently in the State of California to deal with Prop 209 which banned affirmative action in UC and CSU hiring. Of course, the flip side of this workaround being used to promote DEI in the face of identity banning is that it can be used to dilute the effort. There are still a lot more majoritarian applicants than applicants in the A-D categories of NIH’s “interest”, and some of them no doubt have a good story about how they contribute to promoting DEIA.

One might see this as a positive step on the part of the NIH ICs to try to get ahead of anticipated actions from Congress. I do not. I see this as cowardly prior compliance and knuckling under to implied bullying without said bullying ever being applied by the rising right wing political factions. I do not think that appeasing the bullies like this ever really works, it merely emboldens them.

And if this is seen as compromise with legitimate actors in a plural democracy disagreement, well, that doesn’t work either. Compromise never appeases the bigots. It just fires up their side to demand more and more.

To wit: there was some complaining about requiring statements of contribution to diversity in faculty hiring that burbled up into mainstream political discourse a year or two ago. There continue to be efforts to remove those requirements in various states. No doubt this will accelerate in the coming several years.

And proactive compliance has this nasty tendency to lead to even more proactive compliance.

The most recent replacement FOA (PA-25-249 and PAS-25-190) have different language in key areas that appear to reflect further evidence of NIH backing down in cowardice. I already blogged about PAS-25-190 Research Opportunities for New and “At-Risk” Investigators to Promote Workforce Diversity.

As I noted, PAS-25-190 (Posted Nov 8, 2024) now comes with a new statement on “Program Considerations” that says the NIH “may not use race, ethnicity or sex” as criteria for award and insists it will not use such status in the review and award selection process. Say what? How does a Funding Opportunity Announcement have any value if it undercuts the entire purpose and argument for its necessity by saying none of that can be used for evaluation, selection or award?

It was PA-25-249 that got me going today, however. I noticed right away the title had changed to NIAID, NIDDK, NIDA, and NIAAA Research Opportunities for New and “At-Risk” Investigators. Note the lack of “to Promote Workforce Diversity” in the new title. The purpose statement is changed ever so slightly, but significantly. The original versions said “The purpose of this notice of funding opportunity (NOFO) is to encourage researchers from diverse backgrounds to work with their institutions to submit applications for research projects“. The latest version reads “The purpose of this notice of funding opportunity (NOFO) is to encourage New and ‘At-risk’ Investigators from diverse backgrounds, including but not limited to individuals from groups that have been shown to be nationally underrepresented in the biomedical, behavioral, clinical, and social sciences, to work with their institutions to submit applications for research projects“

I note also that NIDA and NIAAA have jumped ship from the NINDS FOA to the latest version of the NIAID one, something that had perplexed me about PAR-25-190. This is a choice and a political statement from my ICs of closest interest. It is very disappointing to see them “leading” in this way, particularly following their early participation in NINDS’ efforts. There are now eight ICs (plus the Office of Research on Women’s Health) participating on PAR-25-190 and four on PAR-25-249. It will be interesting to see if the former eight ICs knuckle under and join the latter four, either in letter or in spirit (by revising language).

This is all sadly predictable. Perhaps it is coming from forces within the NIH who are already against affirmative action and grant award equity, diversity and opportunity. Perhaps it is coming from those who think they are Very Savvy Political Thinkers. Perhaps it is lazy cowards who shy away from any conflict with right wing elements.

I don’t know.

But I do know that this is the beginning, not the end. It will not stop with banning consideration of the identity of the PI on an application. This will start applying to scientific topics as well. We will see targeted FOA not renewed. We may see NIH ICs backing away from certain kinds of research projects just to avoid similar fights. We will see some kinds of science funded that is directed at crackpot theories bandied by political figures.

The NIH will comply.

In advance. Without there even having to be a battle.