What is the Recruitment and Retention Plan to Enhance Diversity?
It is a plan that institutional research training, institutional career development, and research education grant award (e.g., T32, T35, K12, CTSA, and R25) applicants must include in their application. The plan should describe their recruitment and retention efforts to diversify the biomedical, behavioral, clinical, and social sciences workforce through increased participation of talented individuals from underrepresented racial and ethnic groups; individuals with disabilities; and individuals from economically, socially, culturally, or educationally disadvantaged backgrounds. Institutions are encouraged to identify candidates who will increase diversity on a national or institutional basis.
The T34 Minority Access to Research Careers (MARC) and the Career Opportunities in Research Program (COR) are legislatively mandated programs to increase the recruitment of underrepresented minorities into science and thus are not covered by this policy.
What is the NIH Policy to Enhance Diversity and its History?
NIH training grant programs have long required a Plan for the Recruitment and Retention of Underrepresented Minorities. The NIH has also had research supplement programs aimed at the recruitment of underrepresented minorities and persons with disabilities into the scientific workforce. In recent years, the NIH has broadened its efforts in recruitment to include other underrepresented groups such as individuals from economically, socially, and educationally disadvantaged backgrounds.
The NIH policy encouraging the recruitment of individuals who will increase the diversity of the biomedical, behavioral, clinical, and social sciences workforce was first included in the program announcement for Research Supplements to Promote Diversity in Health-Related Research PA-05-015, released on November 19, 2004. It was subsequently included in the program announcement for the Ruth L. Kirschstein National Research Service Award (NRSA) Institutional Research Training Grants (T32) PA-06-468, released on June 16, 2006, and the program announcement for Ruth L. Kirschstein National Research Service Awards for Individual Predoctoral Fellowships (F31) to Promote Diversity in Health-Related Research PA-06-041, released on July 21, 2006. This policy has been included in all research training, fellowship, career development, and research education project award Funding Opportunity Announcements (FOAs) since that time, including, notably, the T32 and K12 linked award components of the Clinical Translational Research Award (CTSA) Request for Application FOAs issued for FY2007 and FY2008. It has now been included in the PHS 398 (Revised 11/2007) application instructions: http://grants.nih.gov/grants/funding/phs398/phs398.html.
What groups does NIH consider to be in need of a special recruitment and retention plan in order to diversify the biomedical, behavioral, clinical, and social sciences workforce?
A. Individuals from racial and ethnic groups that have been shown by the National Science Foundation to be underrepresented in health-related sciences on a national basis (see data at http://www.nsf.gov/statistics/showpub.cfm?TopID=2&SubID=27 and the report Women, Minorities, and Persons with Disabilities in Science and Engineering, 2007, p. 262). The following racial and ethnic groups have been shown to be underrepresented in biomedical research: American Indians or Alaska Natives, Blacks or African Americans, Hispanics or Latinos, Native Hawaiians or Other Pacific Islanders. In addition, it is recognized that under-representation can vary from setting to setting and individuals from racial or ethnic groups that can be convincingly demonstrated to be underrepresented by the grantee institution should be included in the recruitment and retention plan.
B. Individuals with disabilities, who are defined as those with a physical or mental impairment that substantially limits one or more major life activities.
C. Individuals from disadvantaged backgrounds who are defined as:
1. Individuals who come from a family with an annual income below established low-income thresholds. These thresholds are based on family size, published by the U.S. Bureau of the Census; adjusted annually for changes in the Consumer Price Index; and adjusted by the Secretary for use in all health professions programs. The Secretary periodically publishes these income levels at http://aspe.hhs.gov/poverty/index.shtml. For individuals from low-income backgrounds, the institution must be able to demonstrate that such candidates (a) have qualified for Federal disadvantaged assistance; or (b) have received any of the following student loans: Health Professional Student Loans (HPSL), Loans for Disadvantaged Student Program; or (c) have received scholarships from the U.S. Department of Health and Human Services under the Scholarship for Individuals with Exceptional Financial Need.
2. Individuals who come from a social, cultural, or educational environment such as that found in certain rural or inner-city environments that have demonstrably and recently directly inhibited the individual from obtaining the knowledge, skills, and abilities necessary to develop and participate in a research career.
Recruitment and retention plans related to a disadvantaged background (C1 and C2) are most applicable to high school and perhaps undergraduate candidates, but would be more difficult to justify for individuals beyond that level of achievement. Under extraordinary circumstances the PHS may, at its discretion, consider an individual beyond the undergraduate level to be from a disadvantaged background. Such decisions will be made on a case-by-case basis, based on appropriate documentation.
How does the new Recruitment and Retention Plan to Enhance Diversity differ from the former Minority Recruitment and Retention Plan for Institutional Research Training Grants?
The new requirement for a Recruitment and Retention Plan to Enhance Diversity expands on the former requirement of a Minority Recruitment and Retention Plan to include retention and recruitment of disabled students and those from disadvantaged backgrounds.
Is NIH backing away from its commitment to recruiting Under-Represented Minorities in Science?
No. NIH has expanded its emphasis on the importance of recruiting all underrepresented groups into science, including those from underrepresented racial and ethic groups. The NIH believes that a diverse workforce increases the level of public trust, the quality of our education and training programs, and the breadth of our research portfolio. A diverse workforce will permit the NIH to more effectively address health issues of concern to underrepresented groups. Data are available demonstrating that the following racial and ethnic groups are under-represented among research scientists in comparison with their representation in the U.S. population at large: American Indians or Alaska Natives, Blacks or African Americans, Hispanics or Latinos, Native Hawaiians or Other Pacific Islanders. However, NIH is broadening its definition of Diversity Recruitment to include additional groups that may enhance the diversity of the scientific workforce along additional dimensions.
What does NIH expect from applicants with respect to the recruitment and retention of individuals from groups identified under 3.B (disabled) and 3.C (disadvantaged) defined in Question 3?
NIH recognizes that the training community will need to gain experience in the recruitment and retention of groups B (disabled) and C (disadvantaged). Applicants are expected to present plans for the recruitment and retention of these two additional groups. Over the next few years NIH expects that applicants, reviewers, grantees, and NIH staff will gain experience in recruitment and retention in these areas.
Do training grant programs need to recruit students from the 3.C 1 and 2 group (individuals from disadvantaged backgrounds) defined in Question 3?
The answer depends on the scientific career stage of the targeted trainee group. The policy states that the 3.C category, including individuals who come from a family with an annual income below established low-income thresholds and individuals who come from a social, cultural, or educational disadvantaged environment, is most applicable to high school and undergraduate candidates, but would be more difficult to justify for individuals beyond that level of achievement. Therefore, training grant programs that support only graduate-level students and postdoctoral fellows are not required to submit a recruitment and retention plan addressing this group of candidates.
Graduate students and postdoctoral scholars may receive annual wages below the low-income thresholds. Should such students be considered as members of group 3.C1 (individuals from economically disadvantaged backgrounds) as defined in Question 3?
No. Only students who come from familieswith an annual income below established low-income thresholds are eligible. The emphasis is on the family income history not on the current financial status of an individual.
Immigrants from foreign countries may come from families whose incomes in their native country were below the U.S.-defined low-income thresholds. How should institutions consider such individuals for the purposes of their NIH training grant applications?
The institution should consider the background of the individual since their family became residents of the U.S.
How does the institution determine which of the trainees and candidates for appointment as trainees should be included in its diversity recruitment efforts?
Determination of minority/ethnic group status is by self-identification and is voluntary. The institution should ask the trainees or candidates for appointment whether they wish to be identified as a member of a particular minority/ethnic group. By extension, NIH suggests that institutions ask trainees or candidates for appointment to self-identify whether they are individuals with disabilities or are from disadvantaged backgrounds. In these cases, there are precise definitions of who meets the criteria for consideration as part of these groups (See Question 3 and Question 17). The institution should verify that the individual does in fact meet these criteria and request that the individual provide to the institution suitable documentation.
What is included in Biomedical and Behavioral Research?
Biomedical and behavioral research is defined broadly for this program as encompassing scientific investigations in the biological, behavioral, clinical, social, physical, chemical, computational, engineering, mathematical sciences, and other relevant disciplines.
What needs to be included in the Competing Grant Application?
The applicant should include a single section headed, “Recruitment and Retention Plan to Enhance Diversity” This section should address the applicant institution's plans for recruitment and retention touching upon ALL three of the groups specifically mentioned in the Program Announcement: A) Under-Represented Minorities in Science; B) Individuals with Disabilities; and C) Persons from Disadvantaged Backgrounds. NIH recognizes that different approaches may be needed to recruit and retain students from the various groups.
Should there be three separate recruitment and retention plans devoted to each of the groups defined in the program announcement?
No. There should only be a single plan to enhance diversity and not three separate plans. The plan is an aggregate of the efforts to recruit and retain students from underrepresented racial and ethnic groups, students with disabilities, and those from disadvantaged backgrounds, with the overall goal of increasing diversity of the scientific workforce.
Are the recruitment and retention plans to achieve diversity the responsibility of the applicant institution or that of the training grant program?
Both the institution and the specific training grant program (e.g., program director and faculty) should be involved in efforts to diversify the scientific workforce.
Do Competing Continuation Applications need to report trainee diversity data?
Yes. Competing Continuation Applications need to report data on the diversity of their applicants, trainees, and past trainees to the extent that such records are available at the trainee institution. Institutions should immediately begin collecting such data for future reports.
What type of data do I need to include to document program efforts and successes in recruiting individuals from diverse backgrounds?
In the past, NIH specifically asked for data reflecting underrepresented minorities in both competing applications and progress reports. Applications and progress reports should now include data on: A) underrepresented minorities; B) individuals with disabilities; and C) individuals from disadvantaged backgrounds. The same person may be counted in more than one of Groups A, B, and C. For trainees appointed to training grants and institutional career development awards, institutions should count individuals as belonging to the same diversity groups that are self-identified by the individual on the PHS 2271 appointment form.
What formats or tables should I use to report these data in my Competing Application?
The PHS 398 (Revised 11/2007) includes blank table format pages for reporting the tabular data required in Institutional NRSA applications, including data pertaining to the Recruitment and Retention Plan to Enhance Diversity. These tables should be used, rather than any other formats that have been used in the past. All Institutes and Centers of the NIH have agreed to use these table format pages; however, see Institute specific instructions and Funding Opportunity Announcements (FOAs) for additional information.
What documentation does NIH require?
No documentation of specific individuals is required as part of the Competing Grant Application. Data on all groups are to be reported based on voluntary self-identification by applicants and trainees. Institutions should, however, request and retain appropriate documentation from individuals with disabilities and from disadvantaged backgrounds. Underrepresented Minorities (Group A) are to be reported based on voluntary self-identification of applicants and trainees. Native Americans should be persons who maintain tribal affiliation or community attachment (see PHS 398 Personal Data form page). Data on Individuals with Disabilities should be based on voluntary self-identification and the institution's need to provide specific special accommodation as defined by the Americans with Disabilities Act (see http://www.usdoj.gov/crt/ada/). Data on Individuals from a Disadvantaged Background should be based on voluntary self-identification and appropriate documentation provided to the institution. The institution is to certify that the data reported with respect to all three groups are consistent with the definitions given in Question 3. Records of documentation should be kept by the institution, and NIH staff may request this documentation if questions arise about the veracity of the data submitted by the institution.
Why do the instructions provided in some training grant, institutional career development, and research education grant program announcements differ from the instructions included in the current version of the PHS 398?
The instructions in the PHS 398 (Revised 11/2007) are to be followed. Some older FOAs and Institute/Center websites may not have been updated since the change in policy. FOAs and websites will be updated as soon as possible.
Must the Recruitment and Retention Plan to Enhance Diversity address all of the Diversity Recruitment Groups?
Yes. The plan to diversify the biomedical, behavioral, clinical, and social sciences workforce should include information about efforts to recruit and retain individuals from all of the NIH-defined Diversity Recruitment Groups (see Question 3). NIH expects continued efforts to recruit and retain individuals from underrepresented racial and ethnic groups consistent with the policy initiated in 1989, and remains committed to its implementation and success. Under the new policy, NIH has broadened its expectations with respect to recruitment and retention of additional groups.
How will the Diversity Recruitment element of applications be reviewed?
Peer reviewers will be asked to consider the diversity of the applicant and trainee pools and merit of plans in two distinct ways, based on the institution's record and future plans: 1 ) For Competing Continuation Applications, the diversity of the applicant and trainee pool is to be considered as part of the review criterion reflecting the trainee pool. Diversity in the student pool has been associated with improved outcomes in many educational settings. Thus, accomplishments in this area will contribute to the priority score assigned to the application. 2) For all Competing Applications, the reviewers will be asked to comment upon the acceptability of the recruitment and retention plans for increasing diversity. This discussion will occur after the priority score vote on the application has taken place. The comments and recommendation will be recorded as an administrative note.
Will the Diversity Recruitment criterion be reflected in the priority score?
For Renewal (Competing Continuation) Applications, the diversity of the student/postdoc population will be reflected in the priority score. This assessment will not be applied to new applications and the priority score will not reflect the existing diversity of either the applicant or the trainee pool. In both cases, however, the Recruitment and Retention Plans to Enhance Diversity will be evaluated and will be reflected in an administrative note.
Will the reviewers rate the Diversity Recruitment Plan on each of the three recruitment groups?
No. The reviewers will be asked to consider the Diversity Recruitment plan in its entirety. The reviewers may comment upon plans regarding recruitment of each of the three defined groups; however, these three elements will not be separately evaluated. There will be a single assessment reflecting the overall study section's conclusion that the Diversity Recruitment Plan is either Acceptable or Unacceptable.
Can a plan be acceptable in its efforts to recruit members of only one or another of the defined Diversity Recruitment Groups?
No. Plans may vary in their emphasis and may excel more in one area than the others with respect to activities targeting individuals in groups 3.A, B, or C. However, it is not acceptable to focus efforts entirely on one group to the exclusion of the others. The acceptability of the plan is evaluated as a whole with appropriate weighting of various efforts as judged by the reviewers. Since recruitment and retention of underrepresented minorities have been long-standing NIH policies, reviewers have experience in judging plans and identifying a reasonable level of success. While reviewers will have limited experience with plans for recruitment of the other Diversity Recruitment Groups, it is expected that they will become calibrated with respect to this new policy over the next few years.
In judging the merit of the recruitment and retention plan, should reviewers expect that individual personnel such as the PI and mentors involved in the specific training grant applications will be active in this effort, in addition to whatever other activities the applicant institution as a whole undertakes?
Yes. Efforts to recruit and retain individuals that contribute to the diversity of the workforce are specific obligations of those members of the institution specifically associated with the training grant application as well as the institution as a whole.
If the Diversity Recruitment Plan is deemed unacceptable, can an award be made?
No. An award will not be made for any application with an unacceptable Diversity Recruitment Plan. This policy has been in place for several years.
If the Diversity Recruitment Plan is deemed unacceptable, what options exist to address this concern such that an award can be made?
The various Institutes and Centers of the NIH may develop processes by which the applicant may submit an updated Diversity Recruitment Plan that addresses the reviewers' concerns. ICs and their Advisory Councils will develop policies and procedures regarding staff and Council review and resolution of peer review group concerns. An award may be issued after such concerns have been resolved.
Do awarded programs need to report on their Recruitment and Retention Plans to Enhance Diversity?
Yes. Awardees are expected to report on any changes to their Recruitment and Retention Plans to Enhance Diversity as part of the annual progress section of their Non-Competing Continuation Application (PHS Form 2590, Revised 11/2007). Awardees are expected to report on progress in this area, including specific activities undertaken, aggregate numbers of applications, acceptances, enrollments, and retention and completion of training for diversity recruitment groups. Competing Continuation (Renewal) or Supplemental (Revision) Applications should include this information as part of the Progress Report.
Are there forms or tables that should be used to report diversity data on Competing Continuation Applications?
Yes. The PHS 398 (Revised 11/2007) includes tables that should be used to report the numbers of applicants and trainees in each of the Diversity Recruitment Groups.
Are there forms or tables that should be used to report diversity data in Non-Competing Continuation Applications?
Yes. The PHS 2590 (Revised 11/2007) includes a new Trainee Diversity Report that is to be used to submit data on diversity of the appointed trainees, including race, ethnicity, sex/gender, trainees with disabilities, and trainees from disadvantaged backgrounds. This new form replaces the use of the Inclusion Enrollment Report form for this purpose.
Do awarded programs need to report trainee diversity on the PHS 2271 trainee appointment form?
Yes. Awardee institutions should use the updated Appointment Form PHS 2271 (Revised 11/2007) (PDF - 623 KB) to report on their appointees. This form has been modified to provide for voluntary self-identified reporting of individuals with disabilities and individuals from disadvantaged backgrounds, as well as voluntary self-identified race/ethnicity. All personal information will be kept confidential and reported only in aggregate numbers.
Will NIH provide reports on these data?
NIH will periodically publish reports on trends in trainee appointments that will include demographic data reflecting the dimensions of diversity recruitment now to be tracked. Anonymized and aggregated data reports are available from NIH upon request according to well-developed access policies designed to protect the identity of individuals and small groups of individuals.
What are some suggested ways research training grant applicants may recruit and retain individuals to achieve diversity?
Some suggested ways to recruit and retain students from underrepresented minority groups include targeted mailings and personal visits to Historically Black Colleges and Universities, Hispanic Serving Institutions, Tribal Colleges, or other institutions that serve a significant number of minority students (http://www.ed.gov/about/offices/list/ocr/edlite-minorityinst.html), along with participation at national minority student science conferences such as the Annual Biomedical Research Conference for Minority Students (http://www.abrcms.org/index.html) and Society for Advancement of Chicanos and Native Americans (http://www.sacnas.org/). Additional suggestions, including commendable strategies from existing programs supported by the National Institute of General Medical Sciences, may be viewed at http://www.nigms.nih.gov/Training/Diversity/.
As stated earlier, applicants may have limited experience in recruiting students with disabilities and from disadvantaged backgrounds, and there may be limited resources available. However, the following are several sources that may be useful to applicants:
Information relevant to recruitment and retention of individuals from disadvantaged backgrounds may be found at the Health Resources and Services Administration (HRSA) site: http://bhpr.hrsa.gov/DSA/sfag/health_professions/9sdhpcom-01.htm. Most educational institutions and many state agencies also provide information on educational opportunities for individuals from disadvantaged backgrounds.
Will NIH provide funds to cover the costs of Recruitment and Retention Plans to Enhance Diversity?
To the extent that costs associated with recruitment and retention are consistent with the NIH Grants Policy Statement and applicable OMB Cost Principles, they are an allowable expense that may be paid from the Training-Related Expenses budget category. See: http://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part11.htm.
With respect to Training-Related Expenses, the NIH Grants Policy Statement provides as follows: “Funds are provided to defray costs such as staff salaries, consultant costs, equipment, research supplies, staff travel, and other expenses directly related to the training program. Funds are requested and awarded as a lump sum on the basis of the predetermined amount per predoctoral and postdoctoral trainee approved for support. Levels are published in the NIH Guide for Grants and Contracts. Interested applicants should consult the program announcement regarding the specific level for programs such as the short-term training program, the MARC U*STAR program, or the COR program.
Under exceptional circumstances, which can include accommodating the disabilities of a trainee, it is possible to request organizational costs above the standard level. Requests for additional costs must be explained in detail and justified in the application. Consultation with NIH program staff in advance of such requests is strongly advised.”
The above language regarding Training-Related Expenses applies only to awards under the Kirschstein-NRSA program. For allowable expenses under other training, career development, and education grant programs, see the relevant Funding Opportunity Announcement.
For comments or questions concerning this document, please contact the NIH Research Training Office at 301-435-4225 or by email at NIHTrain@mail.nih.gov.