Your institution witnesses an uptick in research support and then a sudden wave of gossip, conflict and bad press hits your campus about harassment allegations in the lab.

Your office is forced to ask the difficult question: How do we manage an award led by a principal investigator (PI) accused of sexual and/or gender misconduct?

The National Institutes of Health (NIH) takes sexual misconduct seriously and has voiced concern about sexual misconduct in the lab. This month, NIH released an approval policy (NOT-OD-18-172) outlining circumstances that may negatively affect a PI’s or other key personnel’s ability to conduct sufficient research. Additionally, in the case that NIH learns about an awardee who is not enforcing the terms and conditions of award, the agency notes, “NIH may take an enforcement action within our oversight authorities, which may include suspending or even terminating the grant.”

Despite one’s personal stance– on the issue of harassment, sexual and/or gender misconduct–, it is important to stay abreast of social change and monitor how shifts in policy directly impact your office’s ability to stay in compliance. Here are three simple best practices to help your office navigate through changing the status of a researcher during times of crisis:

1. Proactively communicate. NIH requires the grantee (typically the institution, not an individual) to notify NIH and seek advance approval for replacement(s) of PIs and/or other senior/key personnel. NIH does not prescribe a timeframe, however, not all federal agencies are alike. A recent National Science Foundation (NSF) harassment policy  paints a clear example of proactive communication with a time sensitive requirement.

​2. Revisit your commitments. As a term and condition of a NIH award, PIs have an Assurance of Compliance with the statutes described in the “Civil Rights Protections” on file. The document enforces federal civil rights laws and provides resources to agencies and grantees that address potential violations. In addition, review internal policies and procedures to ensure your office decision making processes align with funder recommendations and institutional protocol.

3. Breathe. After the initial shock has passed, take a deep breath and know you are not alone. NIH continues to actively monitor, report and help reduce sexual and gender harassment in extramural research. The agency is committed to uphold “high ethical, health, and safety standards in both the conduct of the research we fund and the expenditure of public funds by our recipients,” including adherence to civil rights assurances.

If you would like to discuss this topic offline, feel free to contact Willette B. Fatoyinbo, program manager, at 202.478.4689 or email: fatoyinbow@aascu.org.