The GrantDoctor

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Dear Readers,

Two weeks ago I wrote about changes in NIH National Research Service Award (NRSA) application review procedures. Now NRSA is considering some other changes, this time to its official parental and sick-leave policies. If implemented, the new policies would remove the specific numerical guidelines (30 days parental leave per year for each child born or adopted; 15 days sick leave per year). In place of those limits, NRSA host institutions would be charged with providing NRSA trainees with leave consistent with the institutional policy for "individuals in comparable training positions." This would bring parental and sick-leave policies in line with stated NSRA vacation and holiday policies, which are already linked to the policies of the host institution.

For now this is just a proposal. NIH will implement the new policy only if it is convinced that it will benefit the majority of NRSA fellows. If NIH finds that institutional policies are less generous than the current NIH policy (30 days parental leave, 15 day sick leave), NIH may abandon the proposal. If NRSA fellows are likely to end up with more leave time, NIH will advance the proposal for final approval.

The fact is, though, that many institutions do not have an official, consistent policy for trainees. I know mine didn't. Often leave is negotiated between the trainee and the PI, one day at a time ("My child is not feeling well; can I stay home?"). Even when an institution does have official leave policies, trainees (and even PIs) are often unaware of them. As a practical matter, leave policies are often--usually, perhaps--left to the discretion of the PI. Bottom line: Unless they're made mandatory and given teeth (i.e., an enforcement mechanism), the NIH policies, whether they're changed or not, are unlikely to have much of an effect.

The best approach: The NIH should not drop the numbers. It should, rather, specify a lower limit. So, for example, the NIH should specify that NRSA fellows are entitled to, say, 2 weeks of paid vacation, 15 days of sick leave, 6 weeks of parental leave, and so on--or to the amount of leave granted by institutional policy, whichever is the more generous. This doesn't solve the enforcement problem, but it does provide a specific criterion that PIs and institutions will have to choose to follow or ignore. Ambiguity, it seems to me, is undesirable.

To express an opinion about the new proposal, members of the biomedical community should contact research training officer Wally Shaffer. He prefers to be contacted by e-mail. You'll find his e-mail address at the end of the F32 Program Announcement.

Be Well,

The GrantDoctor

Dear GrantDoctor,Please define the difference between a grant and a cooperative agreement. Also if you could, please identify the difference between deduction alternative, cost-sharing alternative, and addition alternative sections of the FSR. Thanks.Sandy Wells

Dear Sandy,

As you may know, NIH is not only one of the world's largest research-funding organizations; it's also one of the world's largest research organizations. Put another way, NIH's intramural resources are just as impressive as their extramural resources. Other organizations, such as NASA, also have substantial intramural research resources.

NIH, NASA, and other governmental organizations have several mechanisms for developing new resources and new research initiatives. The two mechanisms of interest here are grants (of many varieties) and cooperative agreements. The difference between these mechanisms (a.k.a. "instruments") was made explicit in February 1978, when President Jimmy Carter signed the Federal Grant and Cooperative Agreement Act of 1977, PL 95-224. The act was later amended by PL 97-258 on 13 September 1982.

The act "established Government-wide criteria to distinguish between Federal procurement and assistance relationships with other parties, and it emphasizes that the choice of award instrument should be based on the purpose of the agency-recipient relationship, characteristics of the legal instruments, and related standards and conditions." NIH distinguishes between "procurement contracts" and two kinds of "assistance awards"--grants and cooperative agreements--as follows:

• Procurement contracts are used when the principal purpose of the transaction is the acquisition of property or services for the direct benefit or use of the Federal Government.

• Assistance awards are indicated when the principal purpose of the transaction is to transfer money, property, or services to a recipient to accomplish a public purpose of support or stimulation authorized by law. Under assistance relationships:

  1. Grants are used when no substantial programmatic involvement is anticipated between the Federal agency and the recipient during performance of the assisted activity.

  2. Cooperative agreements are used when substantial programmatic involvement is anticipated between the Federal agency and the recipient during performance of the assisted activity.

In other words, in a cooperative agreement, the government agency (e.g., NIH or NASA) is substantially involved in the work.

NASA defines it in much the same way:

A cooperative agreement shall be used as the legal instrument reflecting a relationship between NASA and a recipient whenever the principal purpose is the transfer of anything of value to the recipient to accomplish a public purpose of support or stimulation authorized by Federal statute, and substantial involvement is anticipated between NASA and the recipient during performance of the contemplated activity. Characteristics inherent in a cooperative agreement include those that apply to a grant, plus the following:

• Substantial NASA involvement in and contribution to the technical aspects of the effort are necessary for its accomplishment. This could involve an active NASA role in collaborative relations, access to a NASA site or equipment, or sharing NASA facilities and personnel. For example, a university investigator could work for a substantial amount of time at a NASA Center, a NASA investigator could work at a university, or when the collaboration is such that a jointly authored report or education curriculum product is appropriate;

• The project, conducted as proposed, would not be possible without extensive NASA-recipient technical collaboration.

What's the difference between the deduction alternative, the cost-sharing alternative, and the addition alternative? These are different ways of dealing with program income. If you have a federal grant and the project funded by that grant generates income, the government gives you three choices: You can deduct that income from the cost of the program (the deduction alternative), you can use the income to fund your institution's share of the cost of the project (the cost-sharing alternative), or you can add that income to the total amount available to spend on the project--but it must be spent on the project (the addition alternative). It's crucial to note that, although the government provides all three of these accounting options, individual programs often specify that a specific alternative must be used.

Be Well,

--The GrantDoctor

Due to the high volume of questions received, The GrantDoctor cannot answer all queries on an individual basis. Look for an answer to your question published in this column soon! Thank you!