We advise all award recipients and authorized organizational officials (AORs) to review NIH’s anti-harassment policies, requirements, and reporting process. Start with this quick refresher, then our summary of an NIH case study on institutional reporting.
How to find help. If you are concerned about harassment or other forms of misconduct at your institution, use NIH’s Find Help guide. You can also check NIAID’s Allegations of Research Misconduct SOP and Reporting Fraud, Waste, and Abuse SOP. Note that Dr. Kelly Poe is NIAID’s Research Integrity Officer.
Anti-harassment for institutions. NIH has Expectations, Policies, and Requirements for recipient institutions to foster an environment free from harassment, including sexual harassment, discrimination, bullying, retaliation, and other forms of inappropriate conduct. Since July 9, 2022, your organization’s AOR must follow Institutional Reporting requirements:
- Your AOR must notify NIH within 30 days after the institution acts to remove or discipline Key Personnel due to concerns about harassment, bullying, retaliation, or hostile working conditions. The report must describe any anticipated impact on NIH-funded awards. (Remember that aspect for the case study below.)
- Note that the institutional report does not replace NIH’s prior approval requirements. Your institution must still obtain prior approval from NIH before making any significant change to the status of key personnel—e.g., access limits, reassignment, or replacement. Refer to NIAID’s Prior Approvals for Post Award Grant Actions SOP and NIH Grants Policy Statement (GPS) sections 8.1.2.6 and 8.1.2.7.
Case study summary. NIH’s Deputy Director for Extramural Research Dr. Michael Lauer posted a Case Study in Research Integrity—Banned From Supervising, Can’t Go in Lab, but No Impact on NIH-Funded Research? on July 17, 2023.
The anonymized case study is based on true experiences. An institution reported to NIH that a principal investigator (PI) caused a hostile and unsafe work environment and would no longer be permitted to supervise staff or trainees. Despite that restriction, the institution concluded that there would be “no impact on NIH-funded work” and planned to keep the individual assigned as PI on multiple awards.
NIH hears similar “no impact” conclusions too often. As Dr. Lauer commented in the post, “How can the NIH-funded work not be impacted if the PI has been found not suitable to supervise others? This situation causes us to worry not only about the safety of the lab environment, but also about the message that this behavior sends to the entire institution.”
From NIH’s perspective, this case study reflects an institutional compliance issue. For proper award stewardship, your institution must designate a PI with the appropriate level of authority and responsibility to lead the project, both intellectually and logistically. Follow NIH GPS section 2.1.2.
Dr. Lauer hopes that institutions with similar situations will “consider other options about who will lead your NIH-supported projects.” In many cases, NIH can work out appropriate measures with your institution to address unsafe working environments. For example, you may need to replace an award’s PI or add more oversight.