Most people would understand if I pushed writing this off. Coming off the back of the worst pandemic in a century, we are now bearing witness to an invasion of a European country by a neighboring force for the first time since the Germans invaded Poland in 1939. What for many of us was unthinkable even a few months ago, is now a reality full of scary possibilities and unanswerable questions. Many of us either have children or friends with children who are eligible for the draft. Could this conflict come to a point where a draft becomes necessary? To be clear, such an action remains unlikely. But it isn’t beyond the realm of possibility that Putin turns his eye to a NATO member, for instance, Ukraine’s neighbor Poland. Let’s just say, I think it is entirely reasonable to ponder these questions and worry a bit about the future.
So why am I writing on this topic now? The answer is simple. The events unfolding in Europe are a stark reminder that most of us live in ‘free’ countries. Those of us in the U.S. are fortunate enough to live in the most prosperous country, during the most prosperous time in it’s history (for instance). Our ability to speak and write freely has never been more secure (discussed here). A path to rise out of a place of financial insecurity has never been more accessible (for example). The health and human condition of our nation has never been better. I know, it’s hard to believe given we just experienced the COVID-19 pandemic, but it’s true! If you don’t believe me, just listen to this Jonah Goldberg interview of Ron Bailey and Marian Tupy (here).
It might not be obvious, but a robust national biomedical science program, led by thousands of independent scientists across hundreds of private and public institutions, is a bastion of freedom. Think about it. Taxpayer dollars, nonprofit foundation funds, and private industry combine to support biomedical scientists, who are tasked with nothing more than to pursue questions that they find interesting or important. They have no real boss telling them what they can or cannot do. So long as you follow basic ethical guidelines, not even ‘the government’ will get in your way. And the benefit of scientific freedom is self-evident: extension of lifespan, decreased fetal-maternal mortality, rapid vaccine development in the midst of a pandemic, gene editing technology to target the untargetable, novel therapies to treat even the most aggressive cancers, the list goes on and on. Simply put, the freedom of pursuit in biomedical science emanates from a free country and scientific freedom is essential for a country’s health and prosperity. So when freedom is threatened in the biomedical sciences, either directly or indirectly, it behooves us in the profession to highlight the danger. This is my attempt to shed light on what I see as a serious threat to scientific freedom in the biomedical sciences. That threat, of course, is the emergence of National Institutes of Health (NIH) policies and programs purported to promote diversity, inclusion, and equity (DIE) and support under-represented minority (URM) scientists.
How does the NIH define ‘diversity’?
The NIH, for understandable reasons, has a long history of requiring the identification of race and ethnicity in clinical research outcome reporting (e.g., here and here). This has undoubtedly led to important clinical findings, for example the observation that African Americans exhibit higher prevalence of systemic lupus erythematosus and other autoimmune diseases. I highlight this because I think it is essential to draw a distinction between a potentially clinically-relevant factor (race, ethnicity, sex) and the nebulous concept of ‘diversity’. It is only recently that the NIH began to introduce (and change, and change again) a definition of diversity and apply it to official funding announcements, new intramural and extramural funding programs, and funding decisions by NIH institution officials. In fact, prior to 2015, a Federal Register Notice released by the Office of Management & Budget (OMB), titled “Revisions to the Standards for the Classification of Federal Data on Race and Ethnicity” was the government-wide standard for classification of race and ethnicity. Confused already? Welcome to the world of navigating US government notices.
The Notice is…. long. Really long. But here is what matters for our purposes:
On January 12, 2015, the NIH released the first in a series of published, and subsequently rescinded, Notices that introduced the concept of ‘diversity’, laid out NIH’s “interest in diversity”, and introduced the language of '“underrepresented populations” as a meaningful determinant in NIH decision-making. The Notices came in three waves. The first notice released in 2015 used the definitions of the OMB Notice and statistics collected by the National Science Foundation’s data and report on Minorities, Women, and Persons with Disabilities in Science and Engineering to define “Underrepresented Populations in the U.S. Biomedical, Clinical, Behavioral and Social Sciences Research Enterprise”. From the notice:
Research shows that diverse teams working together and capitalizing on innovative ideas and distinct perspectives outperform homogenous teams. Scientists and trainees from diverse backgrounds and life experiences bring different perspectives, creativity, and individual enterprise to address complex scientific problems. There are many benefits that flow from a diverse NIH-supported scientific workforce, including: fostering scientific innovation, enhancing global competitiveness, contributing to robust learning environments, improving the quality of the researchers, advancing the likelihood that underserved or health disparity populations participate in, and benefit from health research, and enhancing public trust.
and as justification:
In spite of tremendous advancements in scientific research, information, educational and research opportunities are not equally available to all. NIH encourages institutions to diversify their student and faculty populations to enhance the participation of individuals from groups identified as underrepresented in the biomedical, clinical, behavioral and social sciences, such as:
And what defines underrepresented? The language is familiar:
This first Notice was received with much consternation, but only elicited a vague NIH response on April 8, 2015, titled “Racial and Ethnic Categories and Definitions for NIH Diversity Programs and for Other Reporting Purposes”. This first Notice informed much of the NIH intramural and extramural policy (discussed below) until 2018. So what happened in 2018 that precipitated a change?
In truth, it’s impossible to know what Dr. Francis Collins, the (soon to be ex) director of the NIH, was thinking in 2017 when the planning and discussions for policy change were happening. It’s tempting to speculate that the surprise win by Donald Trump and subsequent ‘turmoil’ in the science community, headlined by the March for Science that occurred in Washington, D.C. in the summer of 2017, informed policymaking by Dr. Collins and the NIH. Indeed, Dr. Collins introduced the annual DIE policy statement which serves to “reaffirm NIH’s policy and pledge” to DIE as well as created the NIH’s Office of Equity, Diversity, and Inclusion (more on them below). Regardless, on January 3, 2018 the first Notice was rescinded and replaced:
On January 25, 2018, it was rescinded and replaced again. And on July 16, 2018, it was rescinded and replaced yet again. These latter revisions were admittedly only modest changes to the initial broadening to how NIH’s diversity policies introduced in the first Notice were applied (again, more below, I promise).
Then, in 2019, a major change occurred. On November 22, 2019, the NIH released its final (for now) Notice of Interest in Diversity, which included a significant broadening of the definition of ‘economic disadvantage’ that myself and several of my colleagues had called for after it was shown, quite convincingly, that NIH funds (in many cases, <1% of allotted money) were not making it to economically disadvantaged Americans (for instance, here). Collectively, the language above on racial and ethnic minorities together with the new language shown below make up what the NIH defines as ‘diversity’ and ‘underrepresented groups’.
So how is the NIH using taxpayer money to support ‘diversity’?
Simply put, the numbers are staggering. To their credit (I suppose?) the NIH is quite open with the funneling of taxpayer money into ‘diversity’: Citing from a recent report published in Nature Medicine, here’s Dr. Collins himself:
On 26 February 2021, the NIH publicly unveiled the UNITE initiative to address structural racism and the systemic barriers to the representation of URGs in biomedicine.
and more…
Funding is a major priority. Two NIH Common Fund funding opportunity announcements commit up to US$24 million in the first three years and $60 million in total for research into transformative health disparities… A third funding opportunity provides up to $30.8 million from 25 NIH institutes, centers and offices to support agency-wide observational and intervention research that addresses the effect of structural racism and discrimination on minority health and health disparities.
Career opportunities for URGs will also be increased, starting with increasing participation of institutes and centers in the NIH Science Education Partnership Award, which targets science, technology engineering and mathematics (STEM) education for children aged 4 to 18. The NIH will expand its interactions with, and support of, Historically Black Colleges and Universities, Tribal Colleges and Universities, Hispanic-Serving Institutions, and other minority serving institutions.
There are also proposed funding increases for four NIH institutes: the National Institute on Minority Health and Health Disparities; the National Institute of Nursing Research; the National Heart, Lung, and Blood Institute; and the Fogarty International Center. These institutes and centers receive disproportionate numbers of applications that would support researchers from underrepresented racial and ethnic groups who research topics related to health disparities.
Dr. Collins outlines numerous initiatives of the UNITE project as well as programs and initiatives being instituted. For example, the National Institute of General Medical Science (NIGMS), will “investigate the effect of structural racism and discrimination on the biomedical workforce”. Keep in mind that NIGMS is the institute generally tasked with funding the most basic of biomedical sciences. Think model organisms (flatworms, fruit flies, etc.) or tissue culture studies. The irony that the most intellectually and scientifically rigorous of NIH institutes is going to ‘investigate the effect of structural racism’ is almost too rich to stomach. What’s worse, the NIH in many of its funding calls now “require applicants to submit, as part of the overall scoring criteria, a plan to enhance diverse perspectives—that is, a summary of strategies to advance the scientific and technical merit of the proposed project through expanded inclusivity.”
At this point, you might say “well, the NIH is a multibillion dollar institute, what’s one program with a few ten million here or there?” It doesn’t stop there. Here again, we can rely on the requirements of MD-715:
Management Directive 715 (MD-715) is a directive to all federal agencies issued in 2003 by the Equal Employment Opportunity Commission (EEOC) to ensure a diverse and inclusive workforce. It is intended to be a strategic tool to assist agencies in developing action plans to establish and maintain effective affirmative programs for equal employment opportunity.
This Report and Plan shows how well NIH’s programs and planned activities have encouraged and increased equity, diversity, and inclusion, and have prevented discrimination in the areas of recruitment, promotion, and retention of members of a particular race, ethnic, or religious background, gender, or for individuals with disabilities.
First, it is worth highlighting how seamlessly the NIH has morphed the original intent of the policy (equal opportunity) to a woke, controversial policy (equity, diversity, and inclusion). Second, it is entirely disingenuous to include ‘religious background’ as part of this, given how the NIH defines diversity (see above) and the fact that not a single NIH report presents data on religious background. Maybe the data exist, but certainly not in the current publicly-available formats. Third, as these reports clearly lay out, the NIH has abandoned (assuming it ever embraced) the notion that someone from a rural state or low income demographic is ‘underrepresented’.
Digging into the meat of these reports, it becomes quite clear that millions of taxpayer dollars have been funneled into programs of questionable legality for at least a decade. For instance, NIH has been funneling money into ‘Diversity Supplements’ for years. Diversity Supplements are basically administratively-reviewed (non-competitive) proposals that provide money to URM graduate students and postdoctoral fellows who are working in a NIH grant-funded lab. These ‘supplements’ amount to a substantial amount of money for an investigator to pay for a student or fellow that is completely inaccessible to budding scientists who don’t meet NIH’s diversity criteria. Furthermore, each NIH Institution issues a grant, called ‘Development for Advancing the Careers of a Diverse Research Workforce’ (or, R25, in NIH parlance), which provides a shocking amount of money to an institution to specifically develop training and mentoring programs solely for ‘diverse’ trainees (details of such grants can be found on NIH RePORTER, for instance, here). The list of these sorts of ‘enhancement’ programs is extensive, including the R15 and U01 (and separate award here), Finally, the NIH runs a program that gives ‘diversity candidates’ an overwhelming advantage when transitioning from a postdoctoral trainee to an independent investigator through the ‘MOSAIC’ program (Maximizing Opportunities for Scientific and Academic Independent Careers Postdoctoral Career Transition Award to Promote Diversity). This program is offered by all NIH Institutes and provides up to two years of full financial support to the candidate during their postdoctoral training and three years of funding once they start their own lab. In total, this typically sums to around more than $1 million per person. This is all in combination with the NIH FIRST (U54) program, that has a “target budget of $241 million over 9 years” to distribute to institutions when they hire faculty from “historically underrepresented groups”. Needless to say, this provides an incredible advantage to a candidate competing for a job.
The NIH rot runs far deeper than even I knew when I started writing this. During Dr. Collins’ tenure, numerous offices and initiatives have been established, including the Office of Equity, Diversity, and Inclusion. In fact, the NIH has eight different offices that focus on diversity issues. It would take me an additional 10,000 words to cover all of the egregious things these different offices do in the name of ‘fighting systemic racism’. But I will leave you with one final example of the sorts of programs your tax dollars are going towards. Starting in 2022, the Sexual & Gender Minority Research Office is accepting nominations for a new award program, the ‘2022 SGM Research Investigator Award Program’. In a profession where every award is considered meritorious and a predictor of future success, these sorts of flatly discriminatory awards cut deep.
How might these NIH actions backfire?
To this point, I’ve tried to keep everything ‘data driven’. I’ve tried to provide representative enough examples to illustrate the programs, policies, and practices that have occurred under Dr. Francis Collins’ reign. There are other actions that some might find even more egregious, but also remain difficult, if not impossible, to prove. For instance, there is a significant fraction of NIH grants that are decided not by peer-review but that are ‘rescued’ by one of the bureaucrats running individual institutes, ranging from the Program Officers who handle individual grants to the Institute Directors themselves (think Anthony Fauci). What criteria these individuals use to save a grant is shrouded in mystery. Only speculation and conspiracy theory remain in place where evidence lacks. But talk to enough colleagues, and you are sure to hear a story about a URM colleague at their institute who’s grant was scored significantly outside the funding range but was still awarded. It certainly isn’t beyond the realm of possibility that race places a role in these decisions, particularly considering repeated public calls from people within the NIH for such actions and even outright admission that such actions happen. I urge everyone to take a moment to read the linked article. It’s pretty jaw-dropping in its bold approach to flaunt Federal law.
So what could the possible ramifications be? People, especially my progressive colleagues, often forget that funding for the NIH has long been a bipartisan priority. In every year of the Obama Administration that featured a Republican-led Senate, the NIH budget was raised above what President Obama requested. But as we have seen in recent years (heck, what we have seen in recent months), anything that becomes a Culture War topic becomes a polarizing topic. And anything that becomes a polarizing topic becomes an unsupportable topic for 50% of this country. With long-time NIH advocates such as Senator Roy Blunt (R - MO) leaving the Senate, the old guard of NIH-supporting Republican Senators is growing thin… and old. Once this old guard is gone, who in a divided Senate is going to support an Institution that is so blatantly misappropriating money to what amounts to reverse discrimination?
It seems not all is lost.
I won’t lie to you all. Things are pretty dire. I wouldn’t be writing this article if they weren’t. But like any other Federal government institution, the NIH is responsive to public outcry. I leave you with one recent example. On May 3, 2021, the NIH released a Notice of Special Interest (NOSI) titled 'NIH Research Project Grant (R01) Applications from Individuals from Diverse Backgrounds, Including Under-Represented Minorities’ (NOT-NS-21-049). This was the first time that the NIH attempted to outright redirect the major NIH funding mechanism, the R01, to URMs specifically. The outcry was immediate. Indeed, my colleagues and I wrote letters to numerous politicians in the House and the Senate. I can only speculate, but I suspect we were not alone. Whether our letters made a difference is unclear, but on October 25, 2021, the NOSI was rescinded.
Now I don’t want to overstate the win. Immediately after the NOSI was rescinded, two of the main orchestrators of NIH’s descent into the 5th Circle of EDI Hell, Marie A. Bernard and Mike Lauer (together with Hannah A. Valentine, see here for instance), published a blog post defending the NOSI and stating “our commitment to ensuring diversity within the extramural biomedical research workforce remains steadfast”. If you don’t feel like reading it yourself (and after everything above, I don’t blame you) it basically says they were caught trying to flout Federal law, but don’t worry, they have all sorts of new EDI initiatives to siphon money to URMs that are far more clever. Sure, I am paraphrasing, but my summary isn’t far off.
So I suspect this isn’t the last time that such flagrantly discriminatory grants come about. And there are still a host of programs (and millions of taxpayer dollars) that are of questionable legality and, at a minimum, are not prudential. But I have to believe that with a bit of public acknowledgement now and a lot of political pressure, the NIH can get back to serving its original intended purpose laid out in the Ransdell Act and signed into law by President Hoover in 1930. Who knows, maybe on NIH’s centennial celebration I will be able to write a follow-up piece celebrating the major reforms instituted by the next NIH Director. But I won’t hold my breath.
Ok, so, Mr. Burke (I know that’s not your real name but I’ll just keep referring to you as Burke or Edmund), let’s posit that I agree with you. Let’s posit that I think the affirmative action is a mistake and that the Supreme Court should overturn Bakke and rule against Harvard (whose admissions policy sounds legitimately racist). Let’s posit that I think the NIH circumventing law to preference people based on race (while ignoring socioeconomic or rural diversity - as the left has done for decades) is wrong and an abuse of my taxpayer dollars (setting aside any libertarian objections I might have to paying taxes or to institutions such as the NIH for the moment). Let’s posit all that. But still, why should I care? Why should I be outraged? I’m not terribly surprised by the facts you lay out. I’d like you to explain to me what the real danger is here. What’s next?
Basically, you’re right that this is a problem, but I think you need to explain to readers what the next shoe to drop is. Because if this is it, there are far worse abuses in the federal government alone. But I think you’re worried about something bigger. I could be mistaken or perhaps I’ve missed something in your piece but it seems to me the real danger isn’t this but something else. For the record, I’d say that Ibram Kendi’s antiracism is actively racist. But so far there isn’t any egregious harm done by the NIH’s grant policy that I can tell (emphasis on egregious). Please take my questions in good faith as I’m genuinely curious.