Harassment and Discrimination Protections in NIH Training Applications

Notice Number: NOT-OD-19-029

Key Dates
Release Date: November 7, 2018

Related Announcements

NOT-OD-15-152
NOT-OD-18-172

Issued by
National Institutes of Health (NIH)

Purpose

The purpose of this notice is to inform the extramural community that applications for National Institutes of Health (NIH) institutional training grants (T15, T32, T34, T35, T36, T37, T90/R90, TL1, TL4) must include a letter on institutional letterhead signed by a key institutional leader that describes the institutional commitment to ensuring that proper policies, procedures, and oversight are in place to prevent discriminatory harassment and other discriminatory practices. This policy applies to applications submitted for due dates on or after January 25, 2019.  The specific section in which the harassment and discrimination protections should appear is detailed below.    

Background

In accordance with Title IX of the Education Amendments of 1972, NIH-supported research and training must occur in a civil, safe, and respectful environment, free from discrimination and unlawful harassment, sexual or otherwise. NIH does not tolerate harassment of any kind, including sexual harassment, at institutions that receive NIH funding, or anywhere that NIH-funded activities are conducted. NIH recognizes concerns about sexual harassment as a significant issue within academic science, engineering, and medicine (NAS 2018).

Policy

This notice serves as a policy reminder that before NIH makes an award to a domestic organization, the Authorized Organization Representative must certify, by means of signature on the application, that the organization has on file with the HHS Office for Civil Rights a one-time Assurance of Compliance (Form HHS-690).

In addition to the aforementioned policy reminder, NIH will include the following instructions in the Funding Opportunity Announcements and Application Instructions for the following types of grant applications:

For Institutional Training (T) Applications (T15, T32, T34, T35, T36, T37, T90/R90, TL1, TL4):
As part of the Letters of Support on the PHS 398 Research Training Program Plan form, applications must now include a signed letter on institutional letterhead from a President, Provost, Dean, Department Chair, or other key institutional leader that describes institutional commitment to the following areas:  

(i)    ensuring that proper policies, procedures, and oversight are in place to prevent discriminatory harassment and other discriminatory practices;  

(ii)   responding appropriately to allegations of discriminatory practices, including any required 
notifications to OCR (see NOT-OD-15-152); and

(iii)  adopting and following institutional procedure for requesting NIH prior approval of a change in the status of the Program Director/Principal Investigator (PD/PI) or other senior/key personnel if administrative or disciplinary action is taken that impacts the ability of the PD/PI or other key personnel to continue his/her role on the NIH award described in the training grant application (also see NOT-OD-18-172 re policy on change in PD/PI status).

This letter to ensure that proper policies, procedures, and oversight are in place to prevent discriminatory harassment and other discriminatory practices will be in addition to the content that is currently included in the Letters of Support describing the applicant institution's commitment to the planned program in order to ensure its success (e.g., providing facilities and a research environment conducive to preparing trainees for successful careers as biomedical research scientists; providing appropriate inter- or multidisciplinary research training opportunities and courses which will allow trainees to acquire state-of-the-art scientific knowledge). 

Combine all Letters of Support into a single PDF file.

This policy is applicable to applications submitted for due dates on or after January 25, 2019. Failure to provide the signed letter will result in withdrawal of the application.

Inquiries

Please direct all inquiries to:

Division of Biomedical Research Workforce
Office of Extramural Research
Website: https://researchtraining.nih.gov
Email: NIHTrain@mail.nih.gov