Try to account for this when reading up on the constant chaos imposed by the new Administration on the NIH.

What I mean by this is not that nobody knows how anything works. It is more that the vast majority of us, from Scientific Review and Program Officers at the NIH, to intramural NIH researchers, to extramural researchers and their administrative support staff do not ever see the whole picture. Many of us extramural researchers are particularly likely to have seen only a very narrow corridor of NIH operations, to have been told various things about it from various sources over the years and to have high confidence that we know “how it works” when in fact we do not. Especially across the vast landscape of the 24 Institutes/Centers with spending authority, their evolved priorities and practices, the diversity of study section practices, etc.

Examples where extramural scientists express incomplete understanding include who the grant is awarded to (aka, who “owns” it), allowable expenditures (frequently our grants administration has truths which are local and not actually NIH regulation or federal law), and what indirect costs are for. That is but a small sample. SROs are often comically unaware of how the dynamics of grant review actually works in a study section even though this is the vast majority of their job. POs are often disastrously ignorant of the realities of extramural researchers trying to maintain a grant funded research program for the length of a career and, of course, many details of how study section review actually works in practice.

I most certainly include myself in this. One pertinent example is that I only recently really understood what SNAP provisions are*. Well, we may be in a position where we have to know a little more about this Streamlined Noncompeting Award Process in the very near future.

The basic principle of SNAP is that at the time of the competing award, the Grants Management Officer negotiates the direct costs for the entire competitive segment, thus eliminating the need to engage in annual direct cost negotiations. As part of that negotiation, NIH staff assures that proposed costs are allowable, allocable, reasonable, and necessary for the project. Since the budget is negotiated for all years of the competitive segment at the time of the initial competing award, annual requirements for financial documentation are streamlined in that only a programmatic progress report, the Federal Cash Transactions Report, and the Financial Status Report are required to enable NIH staff to monitor the scientific and financial aspects of the project.

I hope we will not be in legal fights over whether SNAP makes it easier to terminate SNAP-ineligible grants in the middle of the total competing interval, but I fear we might. I hope we will not get to the point where carryforward of unexpended funds* from one year to the next of the funded award is suddenly prohibited, but the chaos merchants of the new Administration are just throwing everything at the wall to see what sticks.

My more general point of the day is to be a little cautious about what you read on Bluesky, twitter or in various journalism outlets about the NIH. Don’t get all mad when something that sounded authoritative turned out to be incorrect in some detail**. Try to soak up information with some associated mental tags of uncertainty. For those of us involved in the NIH system, try to leave a little room for the consideration that what we thought we knew is actually not correct, whether in small detail or essential concept.

*My misunderstanding was that while I’ve always known that 25% or less of the prior year’s budget could be carried forward to spend in the next year by practice, this had to be actually approved by the assigned program officer. Apparently SNAP-eligible grants are basically pre-approved for 25% or less carryforward. This may be important in the current era.

**E.g., when we are shouting about 1) new grants not being funded right now at the same rate as they were in February 2024 and 2) the suspension of Advisory Council meetings and study sections there is a tendency to conflate these two issues. They are separable issues. The grants that are “missing” from being funded right now are the ones that were submitted last summer, approved by Advisory Councils in Sept-Oct 2024 and could be funded anytime after Dec 1, 2024. Grants not being considered by Advisory Council now are not slated to be awarded until April 1, 2025 or later. Grants not being considered by study sections now wouldn’t have started until July 1, 2025 or later.

The concept of “working below credential” is one I have recently picked up from physicians. The medical industry has a business-like focus and it is, I surmise, quite reasonable to talk about how much a physician gets paid per hour of work, how much other employees get paid per hour of work and how to most efficiently structure a medical operation. When the physicians are being asked to do something that some less expensive could reasonably be doing, it is called being asked to work under credential. With the implication it is wasting money.

In our business of academic science, it is considered a little gauche to describe some tasks as beneath the people who are higher on the pay scale. Which is what “working beneath credential” means. It violates our cultural lean towards egalitarianism, as unrealized as that may be.

Last Friday’s attack on Indirect Costs (more properly known as Facilities and Administrative costs) attached to NIH Grants has renewed interest in discussing just what those F&A charges cover. The attack was also associated with the implication that these charges are unneccessary or reflect institutional/administrative “bloat”.

The salary scales for the University of California can be found here. The annual salary of a Full Professor in the Ladder Rank series (Table 2) ranges from $131,000 to $238,300.

I don’t know all of the job titles and responsibilities but here is a listing at UCSD for a Research Administrator 3 with a salary range of $69,500 – $123,500. Part of this job is “uses skills as a seasoned research administrator to independently develop research proposals, awards, and transactions related to contract and grant management; maintains contract and grant records in compliance with institutional research sponsor policies;“

Here’s a Fund Manager position with a salary range of $69,500 – $123,500. The job description includes “managing the financial and administrative activities of complex extramural, contractual, and internal research projects. This role supports faculty, researchers, and department leadership by ensuring compliance with federal, state, and university financial policies and regulations. Maintain internal tracking systems, generate financial reports, review expenditures for compliance, and provide budget analysis“

Emphasis added.

The time of the newest Full Professor is more expensive than the time of the most expensive of these administrative people. I am assuming here that the time of the administrative people can be charged to IDC, all my experience to date in this system suggests that this is exactly what is supposed to be charged to the F&A. One of the things that administrative support personnel did at my prior institution, with btw “sky high IDC rates”, was to prepare expense reports for any academic travel. E.g., travel to scientific meetings to present data generated on NIH grants and to learn from other people’s research generated on NIH grants. I do not enjoy this support at my current “normal IDC rate” public University. I am responsible for preparing such expense reports to obtain reimbursement for travel charges incurred. Now, I happen to have a hybrid compensation where some of it is paid by the taxpayers of my state and some of it is paid from the research grants. But certainly some of my colleagues are compensated mostly from NIH grants and some mostly from state funds. There’s a range.

In the latter case, expecting Professors to prepare their own expense reports is administrative bloat, but it is picked up by the University. I say “bloat” in the sense that a more expensive person is doing a job/task that a less expensive administrator might be expected to cover. One might also call this inefficiency. This also makes the costs of this task a contribution from the taxpayers of my state to the federal request for research activity. A contribution to the Facilities & Administrative costs.

If any of us prepare expense reports while mostly funded on NIH grants, well, then we are pulling from direct costs (which cover our salary line) that which otherwise “should” be an indirect cost associated with administrators’ work. For that matter, if a lab tasks a technician who is paid 100% from NIH grants with certain annoying administrative tasks* this may come at the same overall cost per hour, but again it is clawing what should be IDC charges back out of direct costs.

Sure, this travel reimbursement issue is just one little thing (although you might be surprised how long it takes to fight through the Concur financial system to successfully submit a travel reimbursement). But the more general point is that there are many real tasks associated with the administrative oversight of a NIH research grant. And if IDC rates are squeezed down, this does not magically make those tasks unnecessary. Which means someone else has to do them. Something else has to be charged for it.

When that someone else is working under credential, so to speak, then the entire system is paying MORE for the same job to be done.

This is inefficiency, not efficiency.

*I have always understood that it is not legal to put purely administrative personnel** on a NIH R-mech grant. Also that these cost “may” be allowable on major projects, such as P-mechs. Here’s a summary from UC Berkeley that comports with my understanding of what I’ve been told in the past.

**Are there workarounds? Sure. I’ve seen purely administrative folks be paid under “research assistant” titles with a job justification that includes “literature searches” or some such semi-plausibly non-bench research activity***. If the PI can get away with it at grant review, they are basically self-clawing from directs that which has been insufficiently covered for them under IDC and the institution’s choices about how to spend it.

***having watched just such a person assist mightily with a prodigious publication output rate (particularly review articles) of a big deal PI, well, I’m not going to say this is unrelated or wasteful.