FASEB Responds to NIH-Wide DEIA Strategic Plan Framework RFI

By: Jacqueline Robinson-Hamm
Thursday, March 31, 2022
On March 24, FASEB submitted comments in response to the National Institutes of Health (NIH) Request for Information (RFI) on a framework for the NIH-wide strategic plan for diversity, equity, inclusion, and accessibility (DEIA). In its comments, FASEB recommended including vulnerable groups outside of NIH’s definition of diverse populations in its efforts, promoting sufficient benefits as a best practice, and analyzing workforce data to understand and address issues pertaining to graduate school debt and faculty pay inequity.

The first objective in NIH’s framework is to implement organizational practices that center and prioritize DEIA in the workforce. FASEB is a strong proponent of promoting positive culture change to create inclusive environments that attract and retain talented scholars in the biological and biomedical sciences. To further NIH’s efforts, FASEB recommended additional disaggregation of intramural workforce demographics by institute and center, job function, and step promotions within pay grades. Additionally, as NIH identifies barriers to equity, FASEB repeated a prior ask to include groups beyond those defined in the Notice of NIH’s Interest in Diversity, such as targets of harassment, sexual orientation and gender minorities, and racial minorities outside the current definition. 

NIH also aims to grow and sustain DEIA through structural and cultural change in the second objective of the framework. In its response, FASEB suggested that NIH generate mechanisms for grantee accountability of commitment to DEIA, and also emphasized promoting sufficient benefits until they become the norm. For example, all postdoctoral scholars, regardless of funding source, should be able to access benefits similar to other employees at their institution. Other benefits of interest include those to create more supportive environments for LGBTQIA+ scientists and working parents. As NIH progresses in this objective, FASEB looks forward to recommendations from the Advisory Committee to the Director Working Group on Diversity Subgroup on Individuals with Disabilities, and implementation of restorative justice practices as recommended by NIH’s Working Group on Changing the Culture to End Sexual Harassment.

Finally, NIH plans to advance DEIA through research as the third objective of the strategic plan framework. Workforce research is a long-standing interest of FASEB’s, and there has been a dearth of NIH-led workforce research initiatives in recent years. FASEB encouraged NIH to once again work closely with economists and social scientists to evaluate the current landscape using both qualitative and quantitative measures. Relying on recent data from National Science Foundation (NSF), FASEB is deeply concerned about the racial and ethnic inequities in debt accumulated during graduate school. FASEB urged NIH to collaborate with NSF to analyze debt levels for fields NIH supports; if disturbing trends persist, creative programmatic solutions must be tested. NSF’s Survey of Doctorate Recipients also indicates faculty pay inequity by gender is still prevalent in the life sciences. Additional research into effective practices to achieve pay equity may help identify solutions to retain diverse faculty.