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NIH RFI 2023 Response

Response to NIH RFI on Re-envisioning US Postdoctoral Research

April 14, 2023

Mayank Chugh, President, Harvard Medical Postdoc Association (HMPA)
mayank_chugh@hms.harvard.edu

Michael Skowyra, Vice-President, Harvard Medical Postdoc Association (HMPA)
michal_skowyra@hms.harvard.edu


On behalf of Harvard Medical Postdoc Association (HMPA)

Harvard Medical School, Boston, MA

 

The Harvard Medical Postdoc Association (HMPA) is one of the largest postdoctoral associations in the Boston Metropolitan Area, and represents over 5000 postdocs from Harvard Medical School (HMS), Harvard School of Dental Medicine (HSDM) and Harvard-affiliated hospitals.

We, the postdoctoral members of the HMPA, are grateful to the National Institutes of Health (NIH) for providing an opportunity to provide direct feedback on the current state of US postdoctoral experiences and challenges, and to offer recommendations for equitably enriching the US postdoctoral ecosystem .

We discuss long-standing issues in the US postdoctoral system and suggest solutions that align with the goals of the NIH for inclusive excellence. Our recommendations are rooted in equity and inclusion and seek NIH-actionable support in setting global standards for a valued postdoctoral appointment.


Fundamental challenges in the US postdoc system                                                                              

A. Varying and opaque titles of postdocs perpetuate systemic disparities

Postdocs are highly skilled young professionals categorised as trainees, research fellows, research associates, research scholars, instructors, or staff, among others. This variation in title creates differences in salary, tax burden, access to benefits (such as health, pension, parental leave, vacations, childcare, etc.), appointment period, and job security, while the nature of work is the same. Such discrepancy in postdoc appointments is long pervasive. The root problems with varying appointment titles have been repeatedly emphasised by the National Research Council in 1969 report; surveys by the National Academies of Sciences, Engineering, and Medicine (NASEM), including the Committee on Science, Engineering, and Public Policy (COSEPUP - a joint committee of the National Academies in 1999); surveys of individual institutions since the 1990s; and more recently, surveys by the National Postdoc Association (NPA). While the NIH refers to postdocs as trainees as per the National Research Service Awards (NRSA), the term ‘training’ for highly skilled labour is exploitative in a historically exclusionary system. Although varying postdoc titles are institutionally regulated due to funding sources, an Advisory Committee to the Director (ACD) in 2014 recommended adjusting benefits policies so that all NIH-supported postdocs on any form receive benefits comparable to institution employees. Following that report in 2015, NIH conducted a survey and issued a request for information (RFI), where commentators and contributors elaborated that NRSA is a contributor to observed benefits inequity and offered recommendations. The failure to act and support highly skilled labour that feeds into the US and global economic system is a bottleneck to academic progress.

 

B. Inadequate compensation creates selection pressure to leave academia

Besides contributing factors to the inequitable compensation policy discussed above, the benefits commonly offered to postdocs are insufficient, especially when the salary is inadequate. As per the latest NPA report, the inequality in postdoc benefits differs based on appointment. While most postdocs receive basic health insurance, access to childcare subsidy, housing support, retirement benefits, adoption assistance, and long-term disability remain poor, threatening family security and responsibilities. To make matters worse, the NRSA stipend guide, which serves as a de facto minimum salary ($56,484 for 2023-24) for postdocs across most US institutions, does not account for geographical cost-of-living. It is notable that the legal minimum salary is $23,660, and postdoc salary data collected from US institutions during 2016-2022 by Gary McDowell confirm that there are postdocs receiving this salary. Many case studies and analyses (more references herein) have highlighted how and why the current NRSA stipend rates are unsustainable for postdocs in high cost-of-living areas such as Boston, New York City, San Diego, San Francisco, Los Angeles, Seattle etc. In our recently published article (already submitted to Tara A. Schwetz, Acting Principal Deputy Director, NIH), we argue that such an unsustainable living burden on highly skilled researchers with negligible job security creates a selection pressure on postdocs, especially with families, dependents, and those who are from historically marginalised backgrounds. Given the diversity, equity, and inclusion goals of the NIH and academic institutions in the US, there is a misalignment with an actionable commitment to reform structural policies that impact postdoc representation. We argue inadequate compensation is creating a driving force/brain-drain for highly skilled researchers transitioning to the industry where they are compensated for their value.

 

C. Differential compensation of intramural and extramural postdocs is not inclusive excellence

The NRSA postdoc stipend scales ($56,484 - 68,604 for 2023-24) are significantly lower than stipend levels for intramural postdocs and visiting fellows ($57,400 - $105,750). Intramural postdocs are rewarded significantly more (~50%) with experience compared to extramural postdocs. Data collected by Gary McDowell suggest that the highest salary for an intramural postdoc in 2020 was $108,932. Such structurally different compensation policies do not reflect NIH’s goals of inclusive excellence.

 

D. Lack of accountability creates a toxic and unsustainable ecosystem

Innumerable reports highlight systemic bias and toxic workplace environments (constituted by bullying, harassment, discrimination, aggression, and manipulation) that disenchant the postdoc experience and harm postdocs’ mental wellbeing. Studies suggest postdocs with intersectional and marginalised identities and on visas are especially prone to mistreatment. In addition, institutions may ‘Minority Tax’ these postdocs. While institutions and the NIH have taken measures recently by setting up secure communication channels, opaque policies for holding PIs and institutions accountable remain a major challenge that NIH must address.

 

Suggested solutions to aforementioned problems

A. Unifying and compensating all US postdocs equitably under one appointment title

We urge the NIH to take a leading stance and remove the exploitative title of ‘trainees’ for postdocs. The NIH should renounce other postdoc titles of fellows, scholars, instructors, staff, etc. We strongly recommend that the NIH use the term ‘Postdoctoral Appointment’, which emphasises an employee position guaranteeing equal benefits as other employees of the hiring institutions.

We also urge the NIH to make the same intramural and extramural postdoc appointments in all aspects of employee benefits and compensation. The postdoc salary and benefits must be compensated in accordance with the geographical cost-of-living and the US economy. In our recent publication, we proposed a salary scale for postdocs in the Boston area upon living wage analysis, consistent with the current General Services (GS) Scale 11. The GS scale is used for federal employees and automatically considers regional and inflation adjustments. The NIH already has built-in adjustments for the GS scale as per diem rates for conference or other work travel for investigators on NIH grants are calculated per the US General Services Administration. We understand that implementing suggested increases in salaries and benefits policies may encounter logistical and financial issues and may reduce postdoc appointments in the country. We argue that a capped postdoctoral appointment may improve the quality of postdoctoral experience and lead to better job security and innovative science. The Janelia Research Campus of the Howard Hughes Medical Institute (HHMI) is an exemplary and successful model with capping in the research teams.

In summary, we propose a ‘compensation package’ for all postdoc appointees (NRSA, intramural and extramural without any bias towards marginalised identities or visa status) that includes:

 

  1. GS11 salaries
  2. Institutional employee status
  3. Benefits package-GS11 adjusted

3.1 Healthcare, including dependents

3.2 Childcare

3.3 Matched retirement

3.4 Adoption assistance and IVF coverage

3.5 Minimum 16 weeks of paid leave for childbirth and adoption

3.6 Relocation costs

3.7 Flexible spending account

3.8 Minimum 3 weeks of annual leave

One might defend and compare postdoc training to medical residency programs where compensation is similarly low, and trainees work hard for a few years to secure a job position. However, residency programs are capped and include intense training programs with job security and high compensation. On the other hand, postdocs struggle to secure a job in the hypercompetitive US academic market, where the assessment of candidates is also plagued with biased measures.

While similar RFI, NASEM, and ACD recommendations have been made repeatedly, NIH has refrained from actionable changes. NIH must commit to valuing the scientific talent and skilled workforce that propel US science and innovation.

 

B. Mandating actions and consequences for NIH-supported institutions

While the NIH has made strides in the recent past by implementing workplace reporting mechanisms, institutional policies and power dynamics outweigh NIH actions–a key issue that plagues the US postdoc experience. We urge the NIH to:

  1. Establish secure paths for postdocs to report workplace behaviour and conduct, and ensure that postdocs in NIH-funded academic institutions are aware of these reporting mechanisms using various communication platforms and during postdoc onboarding.
  2. Conduct independently investigated annual climate surveys in NIH-funded labs and institutions to ensure responsible workplace behaviour, conduct, compensation, and postdocs’ wellbeing.
  3. Ensure postdocs and PIs in NIH-funded institutions take annual/refresher courses on responsible workplace behaviour and conduct.
  4. Annually update all postdocs, PIs, and institutions about any changes in the postdoc compensation packages.
  5. Hold the NIH-funded institutions accountable if PIs or labs (NIH funded or not) exhibit toxic workplace behaviour towards postdocs as defined in Problem D.
  6. Hold institutions accountable if postdocs are not equitably compensated as per NIH postdoc appointment compensation package (proposed solution A).
  7. Ensure the mental and physical safety of postdocs who report maltreatment and to share an actionable timeline with them.
  8. Implement accountability, such as cutting PIs/lab/institutional funding for a defined period and depending on the reporting severity.

Conclusion

We hope NIH will consider the recommendations from our postdoctoral community and others nationwide in enacting actionable changes, demonstrating NIH’s commitment to equity and the future of postdocs. Once again, we are thankful for the opportunity to provide direct feedback from our postdoctoral community. We are willing to collaborate, provide any resources you may need, and take steps together in re-envisioning postdoctoral research in the US.

 

 

 

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