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Vetting Peer Reviewers at NIH's Center for Scientific Review: Strengths and Limitations

WHY WE DID THIS STUDY

Congress, NIH, and Federal intelligence agencies have raised concerns about foreign threats to the integrity of U.S. medical research and intellectual property. In August 2018, Dr. Francis Collins, Director of NIH, raised concerns that peer reviewers were, in some cases, inappropriately sharing confidential information with others. Subsequently, in 2018 Congress provided OIG with $5 million for oversight of NIH grant programs and operations, including the effectiveness of NIH's efforts to protect intellectual property derived from NIH-supported research. This study assesses the strengths and limitations of NIH's Center for Scientific Review (CSR)'s vetting of peer reviewer nominees before they begin reviewing applications for research grants. These peer reviewers have a unique opportunity to access confidential information in grant applications. Because of this access, it is important for NIH to ensure that peer reviewers do not inappropriately disclose or divert confidential information, including intellectual property.

HOW WE DID THIS STUDY

We interviewed NIH staff at CSR, the Office of Extramural Research, the Office of Management Assessment, and the Office of Federal Advisory Committee Policy. We discussed how CSR staff vet peer reviewer nominees and how NIH policy governs that vetting. We also reviewed NIH policy, guidance, and training materials related to vetting peer reviewers.

WHAT WE FOUND

CSR has strengths in its approach to vetting nominees' ability to be effective peer reviewers. CSR verifies nominees' scientific expertise using multiple sources such as their publication and grant histories. It also assesses nominees' communication skills and their ability to leverage those skills in a peer review setting. Peer reviewer nominees are typically well known to CSR even before their nominations, having served as temporary reviewers or having been NIH grantees. This allows CSR to evaluate the nominees on the basis of its past experiences with them. NIH also has controls to ensure that it does not select nominees who have engaged in research misconduct or breaches of peer review. However, CSR's vetting of peer reviewer nominees gives little attention to foreign affiliation beyond requiring a justification for reviewers who are not based in North America. Although nearly all of CSR's peer reviewers work at institutions within the United States, they include both U.S. citizens and foreign nationals. CSR vets all of these reviewers in the same way. CSR generally limits the sources it uses in vetting for other concerns (e.g., legal and moral controversies) to publicly reported information, which is unlikely to reveal such things as undisclosed foreign support.

WHAT WE RECOMMEND

NIH is taking steps to address concerns about foreign threats to research integrity, but it could do more with respect to vetting peer reviewer nominees. We recommend that NIH update its guidance on vetting peer reviewer nominees to identify potential foreign threats to research integrity, in consultation with national security experts, as needed, and that NIH work with the Department of Health and Human Services' Office of National Security to develop a risk-based approach for identifying those peer reviewer nominees who warrant additional vetting. NIH concurred with both recommendations.