Reminder of Your Responsibilities in Upholding Civil Rights

We’ve published many posts discussing the importance of diversity in the workforce. However, one related aspect we haven’t yet discussed here is how you can, and do, contribute to protecting the civil rights for all individuals, and eliminating barriers and providing equal access to activities supported by NIH funds.

Before NIH makes an award to an applicant organization, the organization enters an agreement with the Department of Health and Human Services (HHS) that the institution, as well as any researchers and key personnel supported by NIH funding, will comply with Federal laws that prohibit discrimination on the basis of race, color, national origin, disability, gender and age. This is not just a matter of hiring and recruitment of employees. In fact, it applies to all activities supported by NIH funds. For example, under Title IX, educational programs and training of students and postdoctoral fellows – including admissions, mentoring, grading, and access to benefits – have non-discrimination protections under Federal law.

NIH-supported scientific conferences and meetings are another activity where, consistent with Federal civil rights laws, NIH expects organizers take steps to maintain a safe and respectful environment for all attendees, and welcome participants and presenters from all backgrounds. In fact, a critical component of the application for NIH conference support is how the organizers plan to implement barrier-free access to participation.

We recently issued a reminder and summary of the federal civil rights laws, as well as NIH policies, that apply to all NIH-funded activities. While not all forms of discrimination are protected under federal law, as federal civil rights protections are expanded, these too will be applicable to the NIH-supported research community.

A proposed civil rights regulation that grantees should also be aware of has been issued in conjunction with the Affordable Care Act (ACA). The proposed rule, which is now open for public comment, solicits feedback on how the term “health program or activity” is defined, and what the impact would be on extramural grantees conducting health research. We’d like to encourage the research community to review the Notice of Proposed Rule Making (NPRM) with particular attention to the definition of “health program or activity,” in section (92.4) and provide feedback, as described on the regulations.gov website, before November 9.

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