October 2012

Being clear about transparency

Shortly after I became a graduate student in the chemistry department at Harvard University, the great biochemist Jeremy Knowles assumed the department chairmanship. He instituted semiannual town-hall-style meetings with graduate students at which we could raise issues of concern and Knowles could describe ongoing and planned activities within the department. He attended to the issues that were easy to fix and at least acknowledged the harder problems. These meetings had a substantial positive effect on my morale and that of my colleagues. Although I was only slightly aware of it at the time, this practice made a big impression on my view of the power of transparency in leadership.

A decade later, I found myself in the unexpected position of being a department chairman. I remembered Knowles’ lesson and met with the faculty, staff, postdocs and students regularly and encouraged them to bring their concerns to me. I also revealed as much as was reasonable about our department’s finances so that the faculty and staff could understand both our capabilities and our limitations and help shape our priorities. Should we provide more resources to our departmental facilities or use the funds to hire new faculty or staff members? Without this information, staff participation in such decisions would have been difficult, and the potential level of frustration about why we were pursuing some actions and not others likely would have been higher.

Yet another decade later, I became director of the National Institute of General Medical Sciences at the National Institutes of Health. NIGMS is a substantially more complex organization than a basic science department, with more, and more diverse, stakeholders. Furthermore, I knew from my experience as an applicant, a grantee and a department chairman that NIH policies and procedures can be opaque. Why would a given percentile score result in funding in one year but not the next? Why had my budget been cut despite an outstanding score and a clear justification that I needed the full budget to complete the aims? Once I felt that I had mastered at least some aspects of the NIH’s workings, I sought to share these insights with the scientific community, initially through periodic e-mails and later through a blog, the NIGMS Feedback Loop (1). These efforts were well received by the community, particularly posts that included data curves showing the probability of being funded as a function of percentile score and analyses of scientific output as a function of various parameters. I found the subsequent blog comments and e-mails from scientists and administrators useful for understanding the concerns of the community, collecting some creative ideas and shaping institute policies. I shared my experiences with others in the NIH leadership and have been pleased to see recently posted funding data from some other institutes (2, 3) as well as an informative blog written by Sally Rockey, the NIH deputy director for Extramural Research (4).

Transparency is particularly important for a taxpayer-funded enterprise. Aspects of this were formalized in the NIH Reform Act of 2006, which established the Scientific Management Review Board “to advise the NIH Director … on the use of … organizational authorities” (for example, adding, removing or transferring offices, centers and institutes) and to “identify the reasons underlying the recommendations” (5). When advising on “specific contemplated organization changes,” the SMRB is charged with consulting with stakeholder groups both inside and outside the NIH. This was reinforced in the first report produced by the SMRB, “Deliberating Organizational Change and Effectiveness,” which highlighted the importance of transparency and communication when considering substantial reorganizations (6).

The SMRB embraced this approach in considering the potential merger of the National Institute on Alcohol and Alcohol Abuse and the National Institute on Drug Abuse. The SMRB and its working group evaluating this reorganization consulted extensively with stakeholders, including the advisory councils of the two institutes, scientific and patient-advocacy groups, and the public. Their comprehensive efforts culminated in the report “Substance Use, Abuse, and Addiction Research at NIH” (7). Not everyone agreed with the final recommendation to create a new, merged institute, but the SMRB and NIH leadership took into account considerable information and feedback, and all stakeholders had ample opportunity to provide input before the decision to pursue the merger was made.

The next major reorganization for which the SMRB was enlisted involved making “recommendations for organizing the agency’s existing components to optimize a translational medicine and therapeutics program.” In the course of its deliberations, the assigned working group decided to recommend the transfer of the Clinical and Translational Science Award program from the National Center for Research Resources to a new center focused on translational science. The CTSA program accounted for about 40 percent of the NCRR budget, with the remainder spread over programs focused on animal research resources, institutional capacity building, shared instrumentation and other areas.

Based on this pending recommendation, the NIH leadership decided to abolish the NCRR without further evaluation by the SMRB of the repercussions of doing so, ignoring the principles established by the SMRB only months before. Shortly after the translational medicine and therapeutics report (8) was presented to the full SMRB and approved by a 12–1 margin (I was the sole vote against), the NIH director sent a memo to the secretary of the U.S. Department of Health and Human Services urging her to recommend to Congress both that a new translational center be established and that the NCRR be abolished, as the secretary subsequently did.

Despite several attempts, I was unable to learn of any clear rationale for the abolishment of NCRR or what alternatives had been considered. After months of effort, I turned to another vehicle for promoting transparency in government operations, the Freedom of Information Act (9). In April 2011, I filed a FOIA request with Health and Human Services requesting information about the NCRR abolishment decision. After receiving an initial acknowledgment of my request, I waited a full year until I received the first materials. The e-mails and other communications were substantially redacted, and I have yet to receive all materials responsive to my request. The materials provided to date have not shed much light on the rationale for abolishing the NCRR. I did learn that the secretary of Health and Human Services and her staff were briefed by the NIH leadership about the likely SMRB working group recommendation, including the abolishment of the NCRR, before the SMRB had even met to discuss it and that legal staff at the NIH had objections to even attributing the recommendation for the creation of the new translational center to the SMRB. These discoveries further highlight the lack of transparency in considering these reorganizations.

Given the proposal to transfer a large program from the NCRR to the new translational center, was abolishing NCRR the best course of action? I do not know, but I would argue that neither did the NIH director. In bypassing the transparent, deliberative process established by the SMRB, the NIH director deprived himself and others of the input from different stakeholders that could have informed this important decision before it was made. Furthermore, the manner in which this significant reorganization was conducted substantially undermined the standing of the SMRB as a vehicle for transparency.

I am now examining other situations that would appear to benefit from greater transparency. One relates to indirect costs and facilities and administrative rates at different institutions. Surprisingly, there does not seem to be any available tabulation of such rates, and the ability to locate such information varies substantially from one institution to the next. Given that these costs are the topic of considerable discussion and affect the amount of research federal science agencies can afford to fund, I would argue that having such data readily available would only facilitate accurate analysis related to these issues. A second involves the new NIH program Discovering New Therapeutic Uses for Existing Molecules (10), which provides academic investigators access to study 58 compounds from eight pharmaceutical companies that were tested for safety but then abandoned for their initial therapeutic indication. Although the list of code numbers is available, the structures of the compounds are not, despite their importance for, among other things, computationally screening these compounds against potential targets. Some academic investigators have used creatively a variety of sources to prepare a partial list of these structures (11), but, again, the likelihood of success of the program would seem only to increase through the broad release of the structural information.

In my experience, transparency almost always improves outcomes and has a positive impact on the perceptions and attitudes of even those who do not agree with a decision. Certainly, some information is sensitive and cannot be shared widely without causing difficulties. Furthermore, achieving transparency is not always simple, even when desired, because effective communication and engagement can be quite challenging. Nonetheless, all will benefit if we encourage or even insist on greater transparency from organizations with which we are involved. A well-known part of Jeremy Knowles’ scientific legacy involves wrestling with the concepts of efficiency and perfection in enzymatic catalysis. In the spirit of fostering a different component of his legacy related to the effective operation of organizations, I encourage you to come to me with any questions or suggestions you may have with regard to the operations of the American Society for Biochemistry and Molecular Biology.

  1.   1. https://loop.nigms.nih.gov 
  2.   2. https://deaissl.nci.nih.gov/roller/ncidea/entry/funding_patterns 
  3.   3. http://www.niams.nih.gov/about_us/budget/pattern_fy2011.asp 
  4.   4. http://nexus.od.nih.gov/all/rock-talk 
  5.   5. http://smrb.od.nih.gov/charter 
  6.   6. http://smrb.od.nih.gov/documents/announcements/DOCE_112010.pdf 
  7.   7. http://smrb.od.nih.gov/documents/announcements/SUAA_112010.pdf 
  8.   8. http://smrb.od.nih.gov/documents/reports/TMAT_122010.pdf 
  9.   9. http://www.foia.gov 
  10. 10. http://www.ncats.nih.gov/research/reengineering/rescue-repurpose/therapeutic-uses/therapeutic-uses.html 
  11. 11. http://cdsouthan.blogspot.se/2012/08/ncats.html 


Photo of Jeremy BergJeremy Berg (jberg@pitt.edu) is the associate senior vice-chancellor for science strategy and planning in the health sciences and a faculty member in the computational and systems biology department at the University of Pittsburgh.

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