Gen IC Justification Document

Date: January 9, 2014

To: Office of Management and Budget (OMB)

Through: Seleda Perryman

DHHS Report Clearance Officer

From: Luci Roberts PhD.

Director, Division of Planning and Evaluation

Office of Planning, Analysis, and Communication (OPAC)/Office of Extramural Research (OER)/Office of the Director (OD)

National Institutes of Health (NIH)

Subject: Generic Sub-Study, “NIH Postdoctoral Benefits Survey” (OMB No. 0925-0627)

This is a request for approval by the Office of Management and Budget (OMB), under the Paperwork Reduction Act of 1995, for NIH to conduct a generic sub-study entitled the NIH Postdoctoral Benefits Survey under OMB Control Number 0925-0627, expiration date 2/28/2014. This survey will gather information from NIH funded institutions about benefits offered to postdoctoral researchers.

This survey will assist in the implementation of Executive Order 12862 within the agency.

Executive Order 12862 directs agencies that “provide significant services directly to the public” to “survey customers to determine the kind and quality of services they want and their level of satisfaction with existing services.” The mission of the National Institutes of Health (NIH) is to improve human health through biomedical and behavioral research. The NIH implements this mission by conducting intramural research in its own laboratories; supporting extramural research by scientists at universities, medical schools, hospitals, and research institutes; training basic and clinical research investigators; and fostering and supporting biomedical communication as well as public health information dissemination.

NIH proposed Postdoctoral Benefit survey project is consistent with these goals, and the project will garner important information regarding the experience and satisfaction of our customers.

Use of the Information Collected

The purpose of this survey is to gather information regarding benefits (health, retirement, leave, child care, etc) provided to Postdoctoral Researchers by these grantee institutions. The NIH proposes to conduct a survey of grantee institutions that are member institutions of the National Council of University Research Administrators (NCURA).

Information from the survey will be used by the NIH to assess the types, costs, and source of funding for benefits offered to Postdoctoral Researchers. This information will help the NIH consider policy aimed at equalizing benefits across various NIH support mechanisms and improve consistency with benefits packages available to all Postdoctoral Researchers, irrespective of their source of funding.

Background

A working group of the NIH Advisory Committee to the Director was tasked with developing a model for a sustainable and diverse U.S. biomedical research workforce that can inform decisions about training the optimal number of people for the appropriate types of positions that will advance science and promote health. Based on this analysis and recognizing that there are limits to NIH’s ability to control aspects of the training pipeline, the working group was asked to make recommendations for actions that NIH should take to support a future sustainable biomedical research infrastructure. A report summarizing the workforce data collected and the working group’s recommendations, “Biomedical Research Workforce Working Group Report, A Working Group of the Advisory Committee to the Director”, was published June 14, 2012 (http://acd.od.nih.gov/bmw_report.pdf).

On the subject of Postdoctoral Researchers, the report states that “NIH should require and adjust its own policies so that all NIH-supported postdoctoral researchers on any form of support (training grants, fellowships or research project grants) receive benefits that are comparable to other employees at the institution. Such benefits include paid time off, health insurance, retirement plans, maternity leave etc.” Based on this recommendation, the NIH decided to solicit input from the community on benefits currently provided to postdoctoral researchers [Request for Information (RFI): Inviting Comments and Suggestions on the Implementation of the Recommendations of the Advisory Committee to the NIH Director Working Group on the Biomedical Research Workforce (NOT-OD-13-045); released February 21, 2013, Response Date: April 22, 2013; (http://grants.nih.gov/grants/guide/notice-files/NOT-OD-13-045.html)]. Information from this RFI was expected to help the NIH consider policy that would equalize benefits across various NIH support options and improve consistency with benefits packages available to other employees. However, information gathered from this Request for Information was insufficient for the NIH to be able to describe benefits currently being offered or to consider developing a national “standard” or minimum” recommended benefits package. Thus, there is a need for a survey to collect information about the types and costs of benefits for Postdoctoral Researchers to be issued to NIH stakeholders.

Plan

No personal information is requested from participants; rather, the information requested from respondents in the subject survey pertains to the characteristics and personnel management practices of the institution by which they are employed. Nevertheless, concern for privacy and protection of respondents’ rights will play a central part in the implementation of the surveys. Strict procedures will be followed for protecting the privacy of information gathered from the participants. Participation will be fully voluntary, and the choice not to participate will have no impact on eligibility for or receipt of future funding.

This survey will be administered via the Internet. As appropriate, automated information technology will be used to collect and process information for this survey RTI will observe high standards of information technology (IT) security to protect the privacy, integrity and availability of all computer-based systems and the data they contain. RTI IT security policies and procedures are designed to protect information systems and data from a wide range of risks and will educate their staff to be aware of their responsibilities for ensuring information security and to comply with these policies. RTI also participates with agencies to ensure that their policies conform to agency information security requirements and applicable laws and regulations as required by contract. RTI has System Security Plans for its infrastructures in which it documents how they secure their systems using administrative, technical, and physical controls.

NIH’s Senior Official for Privacy and her office will be consulted throughout the process of conducting a Privacy Impact Assessment (PIA) in the HHS Security and Privacy Online Reporting Tool (SPORT) for all IT systems (e.g. website posting the survey; respondent databases that reside “behind” the website; etc.) associated with the survey, regardless of whether or not they contain personally identifiable information. The NIH Privacy Official determined that he Privacy Act did not apply to this sub-study.

Participation in the survey is completely voluntary, and NIH anticipates a 45% response rate, for a final anticipated sample of 250. The participants are university research administrators employed by institutions that have received NIH research grants and/or National Research Service Awards since 2009. One person will be contacted from each institution. It is estimated that the survey will take an average of 30 minutes to complete and additional research may be required to complete the questions that will take an average of 1 hour, for a total of 1.50 hours per participant.

Estimates of Burden Hours and Costs to the Respondents
Types of Respondents	Number of Respondents	Frequency of Response	Average Time Per Response (Hours)	Annual Hour Burden	Cost
University Research Administrators	250	1	90/60	375	0

The analyses will be primarily descriptive, rather than inferential. Analyses will include cross tabulation of the questions that indicate consistency and validity of responses. Analysis result tables will be designed and produced to present the information in an aggregate format in order to maintain privacy. Bivariate analyses will be conducted to address questions about whether differences exist in responses frequencies across institution types and sizes (for example, are there differences in benefits provided by research institutions versus institutions of higher education, and institutions with large versus small postdoctoral populations). Content analysis will be performed on the narrative responses. The results of the analysis will be disseminated to key management officials at OD, NIH management within six months of the survey's completion. A narrative report with accompanying charts will be provided to NIH management.

Thank you for your full consideration of this sub-study proposal.

3