47
DOCUMENT RESUME 00510 - A0891648] £direct Cost Payments Foregone by Institutions Receiv..ng Minority Biomedical Support Grants--Vhat Can Be Done? HRD-77-55; B-164031(2). March 9, 1977. 38 pp. Report to Rep. Daniel J. Flood, Chairman, House Committee on Appropriations: Labor-Health, Education and elfare Subcommittee; by Robert P. eller, Acting Ccmptroller General. Issue Area: Health Programs (1200). Contact: Human Resources Div. Budget Function: Health: Health Research and Education (552). Organization Concerned: Department of stealth, Educat'on, and welfare; NatJ.onal Institutes of Health. Congressional Relevance: House Committee on Appropriations: Labor-Health, Education and Welfare Subcommittee. Authoriy: Public Health Service Act, as amended, sec. 301(c) (42 U.S.C. 241(c)). National Research Act of 1974, as amended (42 U.S.C. 2891-1). Federal Management Circular 73-6. Indirect cost payments are prohibited on Minority Biomedical Support Progra grants. Estimates of the amounts foregone by grantees as a result of this prohibition were developed. The review was conducted at the National Institutes of Health (NIH) and consisted of examining ecords and interviewing officials. Findings/Conclusions: The section of the appropriation legislation under which the program is funded prohibits the use of grant funds to pay for indirect costs related to grant activities. The indirect cost payments foregone by the 78 institutions that have participated in the program were estimated to be between $1.4 illiov and $4.3 million, with the higher figure probably being more realistic than the lowel- one. The indirect cost rate for fiscal year 1976 was estimated to be about 16%, with the rate increasing at about 2 per year. severO legislative and administrative alternatives are available to allow payment of indirect costs to program grantees. These include treating support program grants like research program project grants and requiring institutions to enter into agreements whereby their research project funds are transferred to inance support program grants. Recommendations: If the subcommittee wishes to ake funds for the support prcgram available for payment of grantee indirect costs, the subcommittee should change the language of future appropriations acts to exempt the program frcm the prohibition against payment of indirect costs. (SC)

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Page 1: DOCUMENT RESUME 00510 £direct Cost Payments Foregone by

DOCUMENT RESUME

00510 - A0891648]

£direct Cost Payments Foregone by Institutions Receiv..ngMinority Biomedical Support Grants--Vhat Can Be Done? HRD-77-55;B-164031(2). March 9, 1977. 38 pp.

Report to Rep. Daniel J. Flood, Chairman, House Committee onAppropriations: Labor-Health, Education and elfareSubcommittee; by Robert P. eller, Acting Ccmptroller General.

Issue Area: Health Programs (1200).Contact: Human Resources Div.Budget Function: Health: Health Research and Education (552).Organization Concerned: Department of stealth, Educat'on, and

welfare; NatJ.onal Institutes of Health.Congressional Relevance: House Committee on Appropriations:

Labor-Health, Education and Welfare Subcommittee.Authoriy: Public Health Service Act, as amended, sec. 301(c)

(42 U.S.C. 241(c)). National Research Act of 1974, asamended (42 U.S.C. 2891-1). Federal Management Circular73-6.

Indirect cost payments are prohibited on MinorityBiomedical Support Progra grants. Estimates of the amountsforegone by grantees as a result of this prohibition weredeveloped. The review was conducted at the National Institutesof Health (NIH) and consisted of examining ecords andinterviewing officials. Findings/Conclusions: The section ofthe appropriation legislation under which the program is fundedprohibits the use of grant funds to pay for indirect costsrelated to grant activities. The indirect cost payments foregoneby the 78 institutions that have participated in the programwere estimated to be between $1.4 illiov and $4.3 million, withthe higher figure probably being more realistic than the lowel-one. The indirect cost rate for fiscal year 1976 was estimatedto be about 16%, with the rate increasing at about 2 per year.severO legislative and administrative alternatives areavailable to allow payment of indirect costs to programgrantees. These include treating support program grants likeresearch program project grants and requiring institutions toenter into agreements whereby their research project funds aretransferred to inance support program grants. Recommendations:If the subcommittee wishes to ake funds for the support prcgramavailable for payment of grantee indirect costs, thesubcommittee should change the language of future appropriationsacts to exempt the program frcm the prohibition against paymentof indirect costs. (SC)

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CRBF IC;E:D I -Not to be cr mLm'd _l t m aAccounting Off"et ocxipt lt the basi st O a so

C) by the Office of C:ongresioI Rdatlos, . .-

~~~C.~~~~~~~~~) ~

i~..-, REPORT OF THECOMPTROLLER GENERALOF THE UNITED STATES

Indirect Cost Payments ForegoneBy Institutions Receiving MinorityBiomedical Support Grants--WhatCan Be Done?National Institutes of HealthDepartment of Health, Education, and Welfare

Institutions awarded grants under the Min-ority Biomedical Support Program are notpaid for indirect costs related to grant activ-ities. The section of the appropriation legis-lation under which the program is funded pro-hibits funds from being used to pay thesecosts. Several alternatives, both legislative andadministrative, are available if the Subcom-mittee on Labor, Health, Education, and Wel-fare Appropriations, House Committee onAppropriations, wishes to change this situ-ation.

HRD-77-55 M A C- 9, 1 19 77

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COMPTROLLER GENERAL OF THE UNITED STATES

WASHINGTON. D.C. 20548

B-164031(2)

The Honorable Daniel J. FloodChairman, Subcommittee on Labor, Health,

Education, and Welfare AppropriationsCommittee on AppropriationsHouse of Representatives

Dear Mr. Chairman:

In accordance with your June 8, 1976, request and sub-sequent discussions with your office, this report discussesthe reasons why indirect cost payments are prohibited onMinority Biomedical Support grants, provides estimates ofthe amounts foregone by grantees as a result of this prohibi-tion, and offers several alternatives for changing this situa-tion.

As requested by your office, we did not obtain writtencomments on the report from program officials. However,the matters presented in the report were, discussed withprcgram officials at the National Institutes of Health, andtheir comments were considered in its preparation.

We plan no further distribution of thi. report unlessyou agree or publicly announce its contents.

Sincerely yours,

ACTING Comptro er Genuralof the United States

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COMPTROLLER GENERAL'S REPORT INDIRECT COST PAY'7ITTSTO THE SUBCOMMITTEE ON LABOR, FOREGONE BY INSTITUTIONS

HEALTH, EDUCATION, AND WELFARE RECEIVING MINORITY BIOMEDICALAPPROPRIATIONS SUPPORT GRANTS--WHAT CAN BE DONE?

COMMITTEE ON APPRCPRIATIONS National Institutes of HealthHOUSE OF REPRESENTATIVES Department of Health, Educa-

tion, and Welfare

DIGEST

According to National Institutes of Healthofficials, the Minority Biomedical SuDF'ortProgram was started because of mandates fromthe President and the Congress to encourage

the development of programs to aid ethnicminorities. The authority for initiating theSupport Program was section 301(c) of thePublic Health Service Act, as amended (42U.S.C. 241(c)), which authorizes the Secre-tary of Health, Education, and Welfare tcaward grants for research projects and forthe general support of research.

Grants awarded for research projects caninclude amounts for indirect costs. Sincefiscal year 1965, owever, appropriation actshave prohibited paying indirect costs ongrants awarded for the general support ofresearch. Using the authority to make grantsfor the general support of research, the In-stitutes initiated the Support Program inDecember 1971. However, because of the prohi-bition in he appropriation acts, Support Pro-gram grantees are not paid for indirect costs,which are costs incurred for common or jointobjectives and not readily identifiable witha research project or activity. (See pp. 1 to 3and p. P.)

according to the Institutes' data, 104 insti-tutions have applied for grants nd 78 insti-tutions have been awarded a total of 343 Sup-port Program grants involving about $31.5million through June 30, 1976. There havealso been 52 grant applications that wererecommended for approval but were not funded.These applications were fie d by 47 institu-tions, 13 of which have never received a Sup-port Program grant. (See pp. 8 and 9.)

HRD-77-55IU.ALAf!LJ Upon removal, the report Hcover date should be noted hereon.

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In estimating the economic impact on SupportProgram grantees, GAO and the Subcommitteeagreed that impact would be measured by theamount of indirect cost payments foregoneby institutions in the program, that is,costs for which institutions would have beenpaid if indirect costs were allowed. (Seep. 1.)

GAO estimated the indirect cost payments fore-gone by the 78 institutions that have partici-pated in the Support Program to be between$1.4 nillicn (using off-campus indirect costsrates) and 4.3 million (using on-campus in-direct cost rates). However, GAO believesthe stimates using on-campus rates are morerealistic than those using off-campus rates.(See pp. 15 to 17.)

GAO also estimated that the on-campus in-direct cost rate for fiscal year 1976 was16 percent and that this rate has been in-creasing about 2 percent a year. The ationalResearch Act (42 U.S.C. 2891-1) will also havean effect on the way indirect costs arecomputed if tihey are to be paid. (See pp.17 and 18.)

Several alternatives, both legislative andadministrative, are available to allcw paymentof indirect costs to Support Program grantees:

-- The language of future appropriation actscould be changed to exempt grants underthe Support Program from the prohibitionagainst paying indirect costs on generalresearch support grants.

-- Since there is no specific authorizinglegislation for the Support Program, actioncould be taken to enact such legislationincluding a provision for paying indirectcosts.

-- The 11 individual institutes could be di-rected to set aside research project fundswhich allow indirect costs for grants onlyto institutions eligible to participate ilthe Support Program.

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-- Since some institutes have entered intoagreements whereby their research projectfunds are transferred tc finance SupportProgram grants, all istitutes could berequired to enter into such agreements.

-- Support Program grants could be treatedlike research program project grants whichare authorized under the Institutes' re-search project authority, and thus granteescould be reimbursed for indirect costs.(See pp. 19 to 22.)

As requested by the Subcommittee, GAO didnot obtain written comments on the report,but it was discussed with National In-stitutes of Health officials. h:ese of-ficials expressed a preference for thealternative of changing the language offuture appropriations acts so that indi-rect costs could be reimbursed to SupportProgram grantees. (See pp. 22 and 23.)

RECOMMENDATION TO THE SUBCOMMITTEE

If the Subcommittee wishes to make fundsfor the Support Program available for pay-ment of grantee indirect costs, GAO recom-mends that the Subcommittee change thelanguage of future appropriations acts toexempt the Support Program from the pro-hibition against payment of indirect costs.(See p. 23.)

Ter Sheet iii

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Contents

Page

DIGEST i

CHAPTER

1 INTROLUCTION AND SCOPEMinority Biomedical Support Program .

Program authority and goals 2Prog..am administration 3Grants awarded. current funding,

and instit .ons supported 4Scope of review 4

2 PROGRAM OPERATIONS 5Eligibility requirements 5Allowed and unallowed costs 5

Types of costs not allowed 7Nature of direct and indirect costs 8Institutions eligible, applications

received, and number supported 3Applications recommended for approval

but unfundedGrants awarded, amounts paid, andminority involvement 9

Minority involvement 9Ability of grantees to compete for

other funds I1Other minority programs 11

A Research Program With Ins:itu-tions Having PredominantlyMinority Enrollments 11

Minority Institutions Science Im-provement Program 12

3 INDIRECT COST PAYMENTS FOREGONE BYINSTITUTIONS IN THE PROGRAM 13

Indirect cost payments foregone 13Cost sharing 14Location of research affects indirect

cost rates 14Amount of indirect cost payments fore-

gone by institutions 15The National Research Act's effect on

the MBS program 17Conclusions 18

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CHAPTER Pae

4 ALTERNATIVES WHICH WOULD ALLOW PAYMENTOF INDIRECT COSTS TO GRANTEES 19

Legislative alternatives 19Change in appropriation legisla-

tion 19Specific authorizing leaislation 19

Administrative alternatives 20Require NIH institutes to provide

funds 20En:ourage use of cooperative agree-

ments 20Authorize program using research

project authority 21Comments of NIH officials 22Conclusions 23Recommendation to the Subcommittee 23

APPENDIX

I June 8, 1976, letter from the Chairman,Subcommittee on Labor-HEW Appropriati3ns,House Committee on Appropriations 24

II Institutions that have applied for MBSgrants by State as of June 30, 1976 25

III List of MBS applications recommended forapproval but unfunded as of June 30,1976 31

IV Estimated indirect cost payments foregoneby State and institution as of June 30,1976 35

V Principal officials responsible for ac-tivities discussed in this report 38

ABBREVIATIONS

DRR Division of Research Resources

GAO General Accounting Office

HEW Department of Health, Education, and Welfare

MBS Minority Biomedical Support

NARRC National Advisory Research Resources Council

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NASA National Aeronautics and Space Administretion

NCI National Cancer Institute

NHLBI National Heart, Lung, and Blood Institute

NIA National Institute on Aging

NIH National Institutes of Health

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CHAPTER 1

INTRODUCTION AND SCOPE

On June 8, 1976, the Chairman of the Subcommittee onLabor, Health, Education, and Welfare, Committee on Appro-priations, House of Representatives, requested that we studythe economic impact on recipient institutions of the Depart-ment of Health, Education, and Welfare's (HEW's) policy ofnot paying indirect costs for Minority Biomedical Support(MBS) grants. (See app. I.) As later agreed, we defined"economic impact" to mean the amount of indirect cost pay-ments foregone by institutions in the program. We did notdetermine to what extent if any this policy has adverselyaffected institutions receiving MBS grants.

MINORITY BIOMEDICAL SUPPORT PROGRAM

According to NIH officials, the MBS program was devel-oped by the National Institutes of Health (NIH) as a resultcf mandates expressed by both the President of the UnitedStates and the Congress.

In a February 22, 1971, message to the Congress on ex-panding opportunities for higher education the President said:

"* * * Black institutions are faced with a historicinadequacy of resources. To help these institu-tions compete for students and faculty with othercolleges and universities, the combined help ofgovernment at all levels, other institutions ofhigher learning, and the private sector must besummoned * * *."

In the report of the Committee on Appropriations,United States Senate, on the appropriations for the Depart-ments of Labor and HEW for fiscal year 1972, the Committeecalled for the General Research Support Branch in NIH'sDivision of Research Resources (DRR) to initiate a pro-gram for black colleges in fiscal year 1972. The Labor-HEW Appropriations Act for fiscal year 1972, as enacted byboth houses of the Congress, retained the budget level setby the Senate for general research support grants ($60.7million), thereby supporting the words of the Senate Appro-priations Committee:

"The Committee encourages * * * the General Re-search Support Branch to initiate a program forthe development of the health sciences at pre-dominantly black colleges which have been unable

1

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to provide adequate preparation for definitivetraining in health research fields and the healthprofessions. Since historically, black studentshave not had equality of opportunity to becomeinvestigators in health research fields and tobecome physicians, dentists, and other healthprofessionals, chiefly due to a lack of ade-quate research and teaching facilities and theinability of black institutions to compete forsufficient numbers of professionals, it is in-cumbent upon the Federal Government to rectifythese inequalities."

While the President and the Congress were primarily con-cerned with the importance of developing and implementinga meaningful program for Blacks, NIH stated that other ethnicminorities were in much the same disadvantaged position.

Program authority and goals

Section 301(c) of the Public Health Service Act, asamended (42 U.S.C. 241(c)), authorizes the Secretary ofHEW to do the foll iJng:

"Make grants-in-aid to universities, hospitals,laboratories, and other public or private institu-tions, and to individuals for such research pro-jects as are recommended by the National AdvisoryHealth Council, or, with respect to cancer, recom-mended by the National Cancer Advisory Board, or,with respect to mental health, recommended by theNational Advisory Mental Health Council, or withrespect to heart diseases, recommended by the Na-tional Heart and Lung Advisory Council, or withrespect to dental diseases and conditions, recom-mended by the National Advisory Dental ResearchCouncil * * * and make, upon recommendation ofthe National Advisory Health Council, grants-in-aid to public or non-profit universities, hos-pitals, laboratories, and other institutions forthe general support of their research * * *."(Underscoring added.)

Grants awarded for research projects can include amountsfor indirect costs. However, since fiscal year 1965, appro-priation acts for general research support grants have pro-hibited paying indirect costs to recipients of these grants.

Using the authority o make grants for the general sup-port of research, DRR officially initiated the MBS program

2

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in December 197i and awarded the first grants in June 1972.However, because of the prohibition in the appropriationsacts, MBS grantees do not receive funds for indirect costs.

NIH hoped that the MBS program would enhance the abilityof minority institutions to compete for biomedical researchgrants. As indicated by the regulations implementing theprogram, NIH plans to accomplish this through (1) increasingthe number of ethnic minority faculty, students, and inves-tigators engaged in biomedical research, (2) broadening theopportunities for participation in biomedical research ofethnic minority faculty, students, and investigators, and(3) assisting in the provision of an appropriate setting inwhich the above two goals can best be accomplished.

Program administration

An MBS grant is composed of several research projectswhich are not necessarily related to one area of science.To receive an MBS grant, an institution must submit a pro-posal to NIH, describing the research objectives and methods,budget estimates, and personnel who will work on the researchprojects. All awards are competitive. However, competitionis among eligible institutions only. Applications are re-viewed by DRR's General Research Support Branch staff andconsultants to ascertain the soundness of the proposal andto assess the benefits which can be expected to accrue bothto the institution and to the national effort in biomedicalresearch.

Applications are then forwarded to the General ResearchSupport Program Advisory Committee for review and recommenda-tion. Following this review, applications are sent to theNational Advisory Research Resources Council (NARRC). NARRCreviews the proposal and makes a recommendation to the Direc-tor, NIH, regarding whether a grant should be awarded. Afterrecommendation by NARRC and approval by the NIH Director, DRRcan award the grant. MBS grants are usually awarded for 3 to5 years. During this time grantees do not have to compete forannual funding. However, if at the end of its grant periodthe grantee wants additional funds or submits a proposal forsupplemental funds, it must compete.

Grantees are required to submit annual progress reportsto DRR. The purpose of these reports is to describe the ac-tivities carried out under the grant and the progress thathas been made in achieving the intended goals of the program.Grantees are also required to submit annual expenditures re-ports on expenditures and obligations incurred during theyear.

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Grants awarded, current funding,and institutions supported

In fiscal year 1976, NIH awarded 90 MBS grants totalingapproximately $8.8 million. These 90 grants were used to sup-port programs at 75 institutions.

SCOPE OF REVIEW

We made our review at the National Institutes of Healthheadquarters in Bethesda, Maryland. Our review consisted ofexamining NIH records, interviewing officials at NIH, theNational Aeronautics and Space Administration, and the Na-tional Science Foundation. In computing indirect cost pay-ments foregone, we used financial data provided by NIH andpreviously established indirect cost rates. We did not re-view the quality of the research obtained from MBS grantsor determine if the program has increased the number of minor-ity biomedical researchers or enhanced the capability ofminority institutions to perform biomedical research. Finally,because of the short time in which we performed our review,we did not verify all the data provided by NIH, nor did wereview any MBS grant projects.

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CHAPTER 2

PROGRAM OPERATIONS

ELIGIBILITY REQUIREMENTS

When the Minority Biomedical Support Program began, eli-gibility was limited to 4-year colleges, universities, andhealth professional schools within the United States and itsterritories in which student enrollments came mainly fromethnic minority groups. Subsequently, the National Institutesof Health learned that most ethnic minority college studentswere enrolled in institutions which were ineligible for agrant under the guidelines. For example, a study conductedby the Division of Researrh Resources stated that only one-third of all Black undergraduates attended predominantly Blackinstitutions; another third were in predominantly Caucasiancolleges, and the remaining were in junior colleges. Abouttwo-thirds of all Mexican-American students were a tendingjunior colleges, as were the majority of Puerto R ans, Cuban-Americans, and American Indians. Thus, it became evident toNIH that under the original guidelines the program was reach-ing few non-Black minorities.

To correct this problem, in September 1973 NIH issued aprogram announcement which stated that eligibility require-ments would be expanded to include 4-year and 2-year institu-tions with a traditionally high (more than 50 percent) minor-ity ;tudent enrollment, 4-year colleges or health professionalinstitutions with a student enrollment including large numbersof minority students (but not necessarily more than 50 per-cent) and American Indian tribes. In order to qualify, in-stitutions having large numbers of minority students (but nota majority) must have demonstrated to HEW that they have acommitment to encourage and assist minority faculty, students,and research investigators. This extension of eligibilitywas formally implemented by publication of regulations onJune 30, 1975.

ALLOWED AND UNALLOWED COSTS

Grants awarded under the program are designed tostrengthen the biomedical research capability of minorityinstitutions. The following are some of the ways in whichgrant funds may be used:

1. Support for faculty "released time"

-- Salaries for time or effort involved in research,as a substitute for a portion of teaching respon-sibilities.

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2. Support for biomedical research ro jects

--Initiation, expansion, and continuation of full-scale and pilot projects.

--Cooperative research projects among investigatorsin several disciplines.

-- Special summer projects.

-- Funds for equipment, supplies, travel, publica-tion costs, and other necessary costs related tothe project.

3. Support for research_ ersonnel

--Salaries of students as research assistants andlaboratory technicians.

--Faculty recruitment programs.

4. Support for research resources

--Costs directly related to the establishment andoperation of central research resources, such ascomputer centers, animal facilities, instrumentshops, etc.

-- Departmental and institutional purchase of equip-ment and supplies for research.

--Renovation of facilities for research.

5. Support for consortia

-- Smaller schools sending students to a larger in-stitution for summer biomedical research.

-- Seminars, workshops, etc.

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6. SuppoLc for research training programs 1/

-- Stipends, tuition, and dependency allowances foruidergtaduate, graduate, and postgraduate students.

-- Costs of the training environment, e.g., facultysalaries, consultants, technical assistance,equipment, travel, publication costs, supplies,etc.

-- Summer training experiences for undergraduateand graduate students.

-- Special research project courses, such as col-lege senior research training courses.

In addition to these costs, grant funds may be usedfor consultant services and purchase of books and periodicalsdirectly related to the research.

Types of costs not allowed

The following are the costs not allowed to be chargedto the program:

---Costs of projects not approved by NIH.

-- New construction.

--Routine maintenance and repairs.

-- Installation of utilities in an unfinished space,furnishings, or finishes to make the area suitablefor human occupancy.

--Multiple purpose travel even though part of thetravel is related to research.

1/Changes made by the National Research Act have had the ef-fect of abolishing the Minority Biomedical Support Program'sresearch training authority. To prevent undue hardship toindividuals in training at that time, a clause in the actallows commitments to pay stipends made before July 12,1974, to be met until the grant expires. As a result stu-dent financial support must now come in the form of asalary or wage under number 3 above (support for researchpersonnel).

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-- Library support.

-- Indirect costs.

NATURE OF DIRECT AND INDIRECT COSTS

Generally, allowable costs under a research grant arecomposed of direct and indirect costs. Direct costs arethose that can be identified specifically with a particularresea:ch objective. Examples include charges for the ac-quisition, care, and use of experimental animals, equipmentpurchases or rentals, salaries and wages of research person-nel, and supplies.

Indirect (overhead) costs are those that have been in-curred for common or joint objectives and therefore cannotbe readily identified with the objective of a particularresearch grant. Operation and maintenance of facilities,depreciation, and administrative salaries are examples of thetypes of costs that are usually treated as indirect costs.Provisions for paying indirect costs are included in grantawards on the basis of an indirect cost rate negotiatedbetween HEW and the recipient institution. (For a more de-.ailed discussion of how indirect costs are allocated toresearch projects see ch. 3.)

INSTITUTIONS ELIGIBLE, APPLICATIONSRECEIVED, AND NUMBER-SUPPORTED

An NIH official estimated that approximately 300 in-stitutions are eligible to participate in the MBS program.Since the program began, through June 30, 1976, 104 institu-tions applied for grants and NIH has awarded grants to 78institutions. (A detailed listing showing the names of theinstitutions that had applied for MBS grants through June 30,1976, appears in app. II.)

APPLICATIONS RECOMMENDED FORAPPROVAL BUT UNFUNDED

According to NIH data, since the inception of the pro-gram there have been 52 grant applications recommended forapproval by the National Advisory Research Resources Councilthat were not funded by DRR because either adequate scienti-fic merit was lacking or funds were not available. Theseapplications involved proposals from 47 institutions. Ofthese 47, 13 have never received an MBS grant. (A listingof the institutions and the number of applications involvedappears in app. III.)

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however, measures the accomplishments of the program interms of the number of students and faculty participatingand the number of papers presented at the Xavier MBS Sym-posium (an annual symposium held at Xavier University inNew Crleans where participants present research papers).

Proeam accomplishments claimed by NIH

As shown below, student participation has nearly quad-rupled since the inception of tha program, and facultyparticipation has almost tripled.

MBS Program Participation

1972 1973 1974 1975

Students 333 737 1,051 1,195Faculty 199 358 499 589

There has also been an increase in the number of MBSstudents, faculty, and investigators attending the XavierUniversity Symposium and the number of papers presentedsince the first symposium was held in 1973, as shown below.According to NIH officials, the quality of the papers pre-sented has improved to a point where they are comparable topapers presented at other scientific meetings.

XavierMBS-Symposium

1973 1974 1975 1976

Number attending 250 470 900 1,300Papers presented 76 165 280 370

In June of 1q76, 399 students participating in theMBS program graduated from their respective institutions,according to NIH statistics. About 74 percent (297) wenton to advanced training. Of this total, 116 were admittedto medical schools, 22 to dental schools, 39 to therhealth related schools, and 120 to other graduate schools.A comparison of these figures with tose of June 1975 isshown below:

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GRANTS AWARDED, AMOUNTS PAID, AND MINORITY INVOLVEMENT

The MBS program was begun with $2 million in fundsoriginally designated for the Health Sciences AdvancementAward Program, which was being terminated. The award pro-gram had been designed to expand the Nation's researchcapability in the health sciences by providing grant supportto institutions already having established biomedical re-search and research training programs. Through June 30,1976, DRR has paid approximately $31.5 million to institu-tions participating in the MBS program, as shown below:

Number oforiginal Number of

Fiscal grants supplement l Total Amountsyear awarded qrants-awar awards paid

72 38 38 $ 2,000,00073 51 - 51 5,000;00074 66 16 82 a/8,048,00075 63 19 82 7,662,96476 76 14 90 8,795,423

Total 294 49 343 b/$31,506,387

a/Includes $1 million release of impounded fiscal year 1973funds.

b/Does not include unobligated balance for fiscal year 1975and fiscal year 1976 of $1,402,325.

The National Cancer Institute (NCI) and the NationalHeart, Lung, and Blood Institute (NHLBI) have provided ap-proximately $1.5 million through June 30, 1976, for MBSprojects. These funds can be used to pay both direct and in-direct costs because projects supported by these institutesare authorized under the research project authority of thePublic Health Service Act, according to an HEW official. Inaddition, since the beginning of fiscal year 1977, the Na-tional Institute on Aging, the National Institute of Allergyand Infectious Diseases, and the National Institute of DentalResearch entered into agreements with DRR whereby they willprovide funds to support MBS projects. The funds provided bythese institutes can L used to pay for indirect costs.

Minor ity involvement

We did not determine if the MBS program has increasedthe number of biomedical researchers or enhanced the capa-bility of institutions to perform biomedical research. NIH,

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June 1975 June 1976

Number to medical schools 78 116Number to dental schools 13 22Number to other health related schools 35 39Number to other graduate schools _99 120

Total to advanced studies 225 297

Total program graduates 293 399

Percent of program graduatesto advanced studies 77% 74%

ABILITY OF GRANTEES TO COMPETEFOR OTHER FUNDS

Our review showed that since the first grants wereawarded in June 1972, 17 institutions participating in theMBS program had successfully competed for other NIH grantson which indirect costs were paid. In 1976 institutions re-ceiving MBS grants also were awarded funds from the followingsources:

Source Number-of-grants Amount

NIH 34 $ 776,385Other Government agencies 66 2,339,566Non-Government organizations 37 __532,545

Total 137 $3,648,496

OTHER MINORITY PROGRAMS

During our review we found programs at two Federal agen-cies whose goals are similar to those of the MBS prLqram. Wewere unable to identify any other programs in the time framein which we conducted our review.

A Research Program-With-InstitutionsHaving Predominantly Minority_ Enrollments

The objectives of this program, sponsored by the NationalAeronatuics and Space Administration (NASA), are to solicitproposals relative to the agency!s mission from colleges anduniversities having predominantly minority enrollments. Theprogram reimburses recipients for indirect costs because NASAbelieves that in order to get research that the agency needs,it should be able to reimburse researchers for the full costsof their work.

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Minority Institutions Science Improvement Program

The objective of this program, sponsored by the Na-tional Science Foundation, is to assist minorities inestablishing scientific careers. Support is provided toacademic institutions serving minorities to strengthen ordevelop effective instructional procedures for preparingstudents in science. This program pays indirect costs onthe basis that grantees are entitled to full reimbursementof costs.

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CHAPTER 3

INDIRECT COST PAYMENTS FOREGONE BY

INSTITUTIONS IN THE PROGRAM

Indirect costs are incurred for broad purposes such asgeneral support and therefore cannot readily be identifiedspecifically with a particular research project or instruc-tional activity. These costs are charged to the functionalcategory accounts and then allocated to those institutionalactivities benefited through a cost allocation process in-volving an indirect cost rate.

An indirect cost rate is the ratio, expressed as apercentage, of indirect costs to a direct cost base. Thisbase usually consists of direct salaries and wages, butoccasionally includes total direct costs, exclusive ofcapital expenditures and extraordinary items. In accordancewith Federal Management Circular 73-6, an indirect cost rateis established on the basis of an indirect cost proposalsubmitted b an institution to the Federal agency responsiblefor negotiating these rates. For most of the institutionsin the Minority Biomedical Support Program, HEW negotiatedthe indirect cost rates. Indirect costs are paid to aninstitution by applying its established rate to the directcosts financed by the research grant, subject to administra-tive and legislative limitations.

INDIRECT COST PAYMENTS-FOREGONE

The phrase "indirect cost payments foregone" refers tothe amount of indirect costs that institutions could havereceived if indirect costs were allowed on MBS grants. Theamount of indirect cost payments foregone was calculatedby applying each institution's approved indirect cost rateto the direct costs financed by the research grant. Fromthis computation we determined the total amount of indirectcosts that the institutions have incurred. This total wasthen reduced by the amount of indirect costs paid by theNational Cancer Institute and the National Heart, Lung, andBlood Institute on projects supported and by 5 percent toallow for cost sharing by the institutes. (See discussionbelow.) This resulted in the amount of indirect costs MBSgrant recipients might have received had they been reimburs-ed for these costs.

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COST SHARING

According to the National Institutes of Health, costsharing represents the portion of project costs which isnot borne by the Federal Government. Cost sharing is a con-tribution by the grantee which may be in cash, in kind(i.e. equipment, supplies, facilities, and manpower), orboth, derived from either the rantee itself or from thirdparties.

Cost sharing has been required on HEW grants since thefiscal year 1966 appropriation act which stated:

"None of the funds provided herein shall beused to pay any recipient of a grant for theconduct of a research project an amount equalto as much as the entire cost of such project."

A grantee may share in the costs of grant-supportedresearch projects either through institutional agreementsor on a project-by-project basis after negotiations betweenthe grantee and the Public Health Service.

The amount of cost sharing may vary in accordance witha number of factors relating to the grantee organization andthe nature of the research effort. On a project-by-projectcost-sharing agreement, NIH guidelines state that a proposalto cost share at a rate of less than 5 percent for the proj-ect period requires justification and approval by NIH. How-ever, HEW's Grants Administration Manual states that in manycases cost sharing of less than 5 percent of total projectcosts would be appropriate in view of an organization's non-profit status and its limited ability to finance the cost ofsuch participation from non-Federal sources. Since indirectcosts are not allowable on MBS grants, the cost-sharingrequirement is fulfilled through the institutions foregoingpayment for indirect costs. However, in computing the amountof indirect cost payments foregone, we had to consider thatinstitutions would have had to engage in cost sharing _fthey recieved indirect costs. In computing indirect costsforegone we assumed that the institutions in the MBS programwould engage in cost sharing at a rate of 5 percent.

LOCATION OF RESEARCH AFFECTSINDIRECT COST RATES

Many institutions receiving MBS grants have on-campus andoff-campus approved indirect cost rates. These depend on

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the actual location where the research is to be performed.Institutions use an on-campus rate to recover indirectcosts on research projects if 50 percent or more of theprojects' base costs will be incurred on campus. Institu-tions can use an off-campus rate when research projectsare performed in facilities not owned or maintained by theinstitution. Generally, MBS institutions' on-campus indirectcost rates are higher than their off-campus rates.

Our review showed that 78 institutions received MBSgrants between June 1972 and June 1976. Of these 78 institu-tions, 68 (87 percent) had approved on-campus indirect costrates. In addition, 24 of the 68 institutions also hadapproved off-campus rates.

Our review did not determine where the institutions con-ducted their MBS projects. Accordingly, we used both on-campus and off-campus indirect cost rates to estimate theamount of funds participating institutions have foregone.

AMOUNT OF INDIRECT-COST PAYMENTSFOREGONE BY INSTITUTiONS

Since indirect costs are not paid on MBS grants, partici-pating institutions may have borne all or part of these coststhemselves. We have had to estimate these costs, since actualcost data was not available for all 78 participating insti-tutions. lso, since certain assumptions had to be made, wehave provided a range of estimated indirect cost paymentsforegone.

To obtain our range of estimated indirect cost paymentsforegone, we made the following computations. For the 68institutiosns having approved on-campus indirect cost rates,we computed the amount of indirect cost payments prohibited($6 million) by multiplying the direct costs paid ($30.6million) by the institutions' approved indirect cost rates.We then computed an average indirect cost rate of 19.7 per-cent for these 68 institutions and multiplied this by thedirect costs ($2.1 million) for the remaining 10 institutionsnot having indirect cost rates. This computation yieldedan estimated $6.4 million in indirect cost payments prohibit-ed for the 78 institutions that had participated in the MBS

program through June 30, 1976. From this $6.4 million wesubtracted oot any indirect costs that were paid by NCI orNHLBI. This gave us the estimated amount of indirect costsfunded by institutions ($6.2 million). Next we made an

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assumption that cost sharing at a rate of 5 percent wouldhave been required if indirect costs had been paid. By re-ducing the total estimated direct and indirect costs ($39.1million) by 5 percent to account for cost sharing, we arrivedat an estimate of the indirect costs foregone ($4.3 million)based on the use of on-campus indirect cost rates. Thissame set of computations was made using the off-campus rates.The following table illustrates the results of our computa-tions.

Using on-campus Using off-campusindirect cost rates indirect cost rates

Percentage Percentageof direct of direct

Amount costs Amount costs

Total direct costs $32,678,480 100.0 $32,678,483 100.0of all MBS grants

Total estimated 6,440,928 19.7 3,319,069 10.2indirect costs

Less: indirect 230,232 .7 105,630 .4costs paid by NCI& NHLBI

Estimated indirect 6,210,696 19.0 3,213,439 9.8costs funded byMBS institutions

Less: cost sharing 1,955,970 - 1,808,264@5 percent oftotal cost

Estimated indirect 4,254,726 13.0 1,405,175 4.3cost paymentsforegone

As shown above the indirect cost payments foregone forthe 78 institutions that have been in the program betweenJune 1972 and June 1976 are estimated to be between $1.4 to$4.3 million. This represents from 4.3 percent to 13 percentof direct costs allowed. (A State-by-State listing of esti-mated indirect cost payments foregone b institutions in theprogram appears in app. IV.)

Although we have considered both on-campus and off-campusrates in computing our estimates, an N1H official stated that

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most colleges and universities in the program actually per-form their biomedical research on campus. In addition, ourreview showed most of the research projects supported byNCI and NHLBI received payments fo. indirect costs based onthe institution's on-campus rate. h'erefore, we believe thatestimates using on-campus rates are ore realistic than thosemade on the basis of off-campus rates. Computations of in-direct costs in the remainder of this report are based onlyon on-campus indirect cost rates.

A trend analysis for the past 3 years based on the on-campus indirect cost rates for the 68 institutions that hadsuch rates showed the following:

Indirect cost Indirect cost paymentsFiscal Direct payments foregone as a percentage_year costs -foregone of-direct costs

1974 $6,532,636 $ 799,751 12.2%

1975 8,521,024 1,226,735 14.4%

1976 8,686,481 1,386,983 16.0%

This trend analysis indicates that if indirect costs hadbeen allowed on MBS grants, NIH would have had to fund an addi-tional 12.2 percent for fiscal year 1974, 14.4 percent forfiscal year 1975, and 16 percent for fiscal year 1976. Theanalysis also shows that the average indirect cost rate hasbeen increasing about 2 percent per year. This parallels theincrease that NIH has experienced as a whole on all of itsproject grants from fiscal year 1972 to fiscal year 1976.

THE NATIONAL RESEARCH-ACT'SEFFECT ON THE MBS PROGRAM

If NIH subsequently pays indirect costs on MBS grants, theNational Research Service Award Act of 1974, as amended (42U.S.C. 2891-1) could affect the amount of indirect costs to bepaid. The act authorized the Secretary of HEW to make NationalResearch Service Awards for training of individuals to performbiomedical and behavioral research, and amended the PublicHealth Service Act by abolishing the training authority pre-viously authorized by section 301.

Prior to the passage of the National Research Act, MBSgrants could be awarded for research training programs andstudents participating in the program could receive financial

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support in the form of stipends. However, stipends could notbe included in the base for computing indirect costs whenthe base used was salaries and wages. According to HEW andNIH officials, the effects of abolishing the training author-ity for the MBS program means that student financial supportmust now come in the form of either a salary or a wage in-stead of a stipend. Salaries and wages are an acceptable basefor computing indirect costs, and most of the institutions inthe program that have indirect cost rates use this as theirbase. Thus, increasing the amount of salaries and wages couldincrease the base for computing indirect costs, which in turncould increase the indirect cost amount.

To prevent undue hardship to individuals presently atthat time in training, a clause in the act allows commitmentsmade before July 12, 1974, to continue paying stipends untilthe grant expires. In 1976 there were 14 institutions thatreceived grants after July 12, 1974, and received funds forsalaries and wages for research participants and laboratoryassistants. In 1977 there will be 36 institutions whoseoriginal grants will expire and which must reapply for addi-tional funding if they want to stay in the program, an addi-tional 12 by 1978, and another 13 by 1980.

CONCLUSIONS

We estimated that the indirect cost payments foregonefor institutions in the MBS program have been between $1.1and $4.3 million based on off-campus and on-campus indirectcost rates, respectively. However, it should be noted thatthe estimates of the indirect costs foregone using the on-campus rates may be more reliable and realistic of the im-pact that the policy of not paying indirect costs has hadon nstitutions, because (1) 87 percent of the institutionsin our review had on-campus indirect cost rates whereasonly 31 percent (24 out of 78) had off-campus rates, (2)most colleges and universities in the program actually per-form their biomedical research on campus, according to anNIH official, and (3) most of the research projects supportedby NCI and NHLBI received payment for indirect costs basedon the institution's on-campus rate.

A trend analysis showed that the average indirect costrate was 12.2 percent, 14.4 percent, and 16 percent forfiscal years 1974, 1975, and 1976, respectively, and is in-creasing at a rate of about 2 percent a year. Should indirectcosts be allowed, the effects of the National Research Actshould also be considered.

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CHAPTEP 4

ALTERNATIVES WHICH WOULD ALLOW

PAYMENT OF INDIRECT COSTS TO GRANTEES

As part of our review, we considered what possible ac-tions could be taken which would result in Minority BiomedicalSupport Program grantees being reimbursed for indirect costs.In this regard, we considered five alternatives which wouldallow grantees to receive payment for indirect costs. Twoalternatives require legislative action, while the other threecould be done through administrative actions of the NationalInstitutes of Health. Each alternative and any significantissues associated with it are discussed below.

LEGISLATIVE ALTERNATIVES

Since fiscal year 1965, appropriation acts for generalresearch support grants have specifically prohibited payingindirect costs to recipients of general research supportgrants. This prohibition extends to recipients of MBS grantsbecause these grants are considered by NIH to be awarded underthe authorization for general research support grants. Eitherof the two legislative alternatives discussed in this chaptercould be pursued to change this situation.

Change in appropriation legislation

The language of future appropriation acts could be wordedso that MBS program grants would be exempt from the prohibi-tion against paying indirect costs. This alternative is onewhich could be initiated by the Subcommittee. The followinglanguage could be used:

"To carry out, except as otherwise provided, sec-tion 301 of the Public Health Service Act withrespect to research resources and general researchsupport grants, Provided, that withthe exception of funds for te Minority BiomedicalSupport Program, none of these funds shall be usedto pay recipients of the general research supportgrants programs any amount for indirect expenses inconnection with such grants."

Specific authorizing legislation

As noted earlier, the MBS program is currently carriedout under section 301(c) of the Public Health Service Act,

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as amended (42 U.S.C. 241(c)), as there presently is nospecific authorizing legislation for the program. Actioncould be taken to enact legislation specifically authoriz-ing the MBS program, including provision for payment ofindirect costs. Such action would still require that appro-priation legislation not prohibit use of funds for indirectcosts.

ADMINISTRATIVE ALTERNATIVES

There are some administrative actions which NIH couldtake to permit payment of indirect costs incurred by MBSprogram grantees. In reviewing the three administrativealternatives, the Subcommittee will note that each has aparticular disadvantage or issue which must be considered.

Require NIH institutes to provide funds

Since research project grant funds can be used to pay forindirect costs, the Director of NIH could require each of the11 NIH institutes to set aside a certain amount of these fundsfor awards of grants for biomedical research to minority insti-tutions and institutions with substantial minority enrollment.This alternative was previously considered by NIH, but was notadopted because it would create, in effect, 11 minority supportprograms where there is now 1. According to NIH officials,administrative costs under this concept could increase substan-tially. Also, this concept was used previously for anotherprogram, but according to NIH officials it proved cumbersomeand was changed.

Encourage use of cooperative agreements

As stated on pages 9 and 10, five of the NIH instituteshave entered into agreements whereby funds are transferred tothe Division of Research Resources to support MBS grants, whenproposals relate to the objectives of these institutes. Re-views to determine the scientific merit of institute-supportedprojects are conducted by the General Research Support ProgramAdvisory Committee, DRR, as is any other proposal for an MBSgrant. Since institute-supported proposals are authorizedunder the research project authority of the Public Health Ser-vice Act, grantees are entitled to receive indirect costs,according to a HEW official.

NIH could require the remaining institutes to enter intoagreements similar to those already adopted. This would pro-vide additional funds which could be used to pay indirect costs

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but would have no effect on the funds appropriated for theMBS program. Also, DRR officials stated that obtainingsimilar agreements from the 6 other NIH institutes would beadministratively burdensome.

Authorize program using research project authority

NIH officials have said that MBS grants are most similar toresearch program project grants which are awarded for supportof broadly based and usually a long-term program of researchactivity. These grants are flexible, usually directed towarda range of problems within a broad category, and have a centralresearch focus rather than a specific single purpose. An MBSgrant is similar to a research program project grant because it iscomposed of several research projects. However, MBS grants aredifferent because the research projects are not always relatedto one area of science, as is the case with the program projects.Program project grants are authorized under the research projectgrant authority of section 301 of the act. Thus, grantees areallowed to be reimbursed for indirect costs.

Another administrative alternative would be for NIH tooperate the MBS program under the authority to award researchprogram project grants. However, before this can be done thereare certain issues that must be confronted.

According to section 475 of the Public Health Service Act,the Secretary of HEW is required to conduct appropriate scien-tific peer review of applications for biomedical and behavioralresearch grants. This peer review is to be conducted in a man-ner consistent with he system for scientific peer review ineffect at te time the section was enacted (July 23, 1974). Thepeer review system in effect on July 23, 1974, required eachgrant application to be reviewed by a study section composed ofauthorities in selected scientific fields. Each application isreviewed and applications recommended for approval are assigneda numerical priority score (between 100 and 500) to indicatescientific merit in relation to the "state of the art" of aparticular research area. The lower the priority score, thegreater the scientific merit of the application. Following thestudy section review, all grant applications are forwarded to thenational advisory council of the appropriate institute. Eachinstitute has a national advisory council, which must recommendapproval of grant applications before they can be funded. Thesecouncils are composed of leaders in fundamental and medicalscience, education, and public affairs. The primary respon-sibility of these councils is to evaluate whether applications

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relate to the mission and the needs of the respectiveinstitutes. After the advisory council review, the insti-tutes consider all recommended applications for funding.

MUS roposals compete only among themselves for funds.Proposals undergo scientific peer review by DRR's GeneralResearch Support Program Advisory Committee. According toan HEW official, the legislative history for section 475seems to indicate that the method of scientific peer reviewreferred to is that conducted by the various study sectionsresponsible for the areas of medicine of the NIH institutes.Thus, if the program were to be conducted under the researchproject authority of section 301, different peer review re-quirements may apply that would necessitate changes in theprogram as it is now operated. Proposals for MBS grants mayhave to undergo peer review by the study sections outside ofDRR and thus would have to compete with all other NIH propo-sals. According to an NIH official, very few institutions wouldthen be able to qualify for grants.

In addition, section 301(c) requires that the nationaladvisory councils for cancer, mental health, heart disease,or dental disease recommend proposals in their respectiveareas. Recommendations for MBS proposals are made by theNational Advisory Research Resources Council, the advisorycouncil for DRR. According to an NIH official, the issue ofwhether NARRC has sufficient expertise to review projectsrelating to the above areas should be addressed. This coun-cil is composed of 14 members, most of whom are experts inthe fields of research related to programs of DRR (animalresources, general clinical research centers, biotechnologyresources, and general research support programs).

The above issues demonstrate the complexities involvedif NIH should take administrative action to authorize theMBS program under the research project authority of section301(c) of the Public Health Service Act.

COMMENTS OF NIH OFFICIALS

As agreed with the Subcommittee, we obtained oral com-ments from NIH uficials on our draft report. These offi-cials provided us with additional facts on the MBS programthat were incorporated into the report. In addition, the NIHofficials commented on the five suggested alternatives toallow MBS grantees to be reimbursed for indirect costs.

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Of the two legislative proposals, NIH officials expresseda preference for amending appropriations legislation along thelines we suggested. In the view of NIH officials, the alterna-tive of enacting authorizing legislation would not guaranteethat indirect costs could be paid because appropriation legis-lation could still include a restriction. An NIH official stat-ed that the administrative alternatives suggested would "createadded administrative burdens and be too complex and impracticalto administer." In addition, the official commented that thealternative of encouraging the institutes to set aside fundsand using cooperative agreements would not solve the problem be-cause only the funds provided by the institutes would be able tobe used to pay indirect costs. DRR funds used for MBS grantswould still not be available to be used to pay indirect costs.

CONCLUSIONS

Five possible courses of action have been suggested forconsideration in allowing the future reimbursement of indirectcosts incurred by MBS program grantees. We agree with NIHofficials that all of the administrative alternatives wouldcreate added administrative burdens and could take a long timeto implement. Also, the alternative of encouraging the use ofcooperative agreements is only a partial solution, since therewill still be funds which cannot be used to pay indirect costs.

With regard to the two legislative alternatives, we be-lieve that changing the language of future appropriations atsoffers the better course of action for two reasons. First, itis an action which can be initiated by the Subcommittee. Sec-ond, enacting authorizing legislation will likely take more timeto achieve and appropriation legislation would still have to beprovided to carry out the authorizing legislation.

RECOMMENDATION TO THE SUBCOMMITTEE

If the Subcommittee wishes to make funds for the MBS pro-gram available for payment of grantee indirect costs, we recom-mend that the Subcommittee change the language of futureappropriations acts to exempt the MBS program from the prohibi-tion against payment of indirect costs.

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APPENDIX I APPENDIX I

eAjoITY MINOMIY maes

GoORGE H. MAHON. TEX.. A. c_,nin, MICH.

JAMIE ..V WHIITTON. MiSS. SqLIO C WI. MAW.IHI,.VO OY OmW ML o,

XET L . a. FA. _ .SI.. rKAN

CT" a' PASMAK LA. JOSEPH . Mc DADE. PA.

JOE L. trIN r . *MAK AmWS. N. DA.

KYWArn P. Le, MASS. on of t)e nittb tattW L. TA "Ur.

iIAMI H. HCHE. IK. JACK EDWAIDO, AL.A.

'DAMIEL. .00D. PA. NNMt C. MC IAt N.Y.

TOM "TElD, OKLA. Y 5 Wo4ut of prttntati . , .

O"GE it. lI LL KEINTHN ROBiNSI. VA.

JOHN . LACK. W. VA. CASSPCE MILLIE *HIO

L, lYTJ. G^. . Committee o 2IppropriationDs cLA " CJn PA.NEAL SMITH. IOA C. W. L YUlmS ELA.

RSIDET N. MAIMS. CONIH _ r f JACK . *KEMP. HN

SOEN P. ADDAR, N.V. E45libWon,, 3.0. 20515 WILLIAM 1L. ASIY CLO-S

EDWARD J PAYTWI. J. CLAIM W. 8USSXEE CAU.

CLaU DE. LO'· L .SONY r. VATES . ILuE A E DRORrANE . EA&Iv. COL CAK AD "TA DIRECTORDAVID . 0June , 1976 KTH -. MIND

KOWAID M. TLE.IIIS" . . Y. iOES, .

J. C I DcTOL "41ts. - xWID .'UN. ,aM . M

MC IAY. UTAH

SELL D. ILI , MO.

EDWARDY I. IICI II.Y.

VYC SATI IHI .WAIT, Wi CA' 1jOD P MIsTHA. PA.ID TXKA. MICH.

JEl DcML. ONS,

M. ALI. MiT.

441 G Street, N.W.Washington, D.C. 20548

Dear Mr. Staats:

This is to call your attention to the language contained on page 44

of the report on the 1977 Labor-HEW Appropriation Bill.

Specifically, the Committee requests the General Accounting Office to

conduct a factual and objective study of the actual economic impact on

the recipient institutions of the policy of not paying indirect costs onMinority Biomedical Support grants.

I would greatly appreciate having your report prior to February 1, 1977.

S ic fr2ly,

Subcommittee on Labor-HEWAppropriations

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APPENDIX II APPENDIX II

INSTITUTIONS THAT HAVE APPLIED FOR

MBS GRANTS BY STATE AS OF JUNE 30, 1976

ALABAMAAlaama A&M University, NormalAlabama State University, MontgomeryOakwood College, HuntsvilleStillman College, TuscaloosaTalladega College, TalladegaTuskegee Institute, TuskegeeMiles College, Birmingham

State total: 7

ARIZONA

Navajo Health Authority, Window Rock

State total: 1

ARKANSAS

Arkansas A M & N College, Pine BluffPhilander Smith College, Little RockUniversity of Arkansas at Pine Bluff, Pine Bluff

State total: 3

CALIFORNIA

California State University, Los AngelesUniversity of California, San DiegoUniversity of California, Santa CruzCharles R. Drew Postgraduate Medical School, Los Angeles

State total: 4

DELAWARE

Delaware State College, Dover

State total: 1

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APPENDIX II APPENDIX II

DISTRICT OF COLUMBIA

Federal City College, D.C.Howard University, D.C.District of Columbia Teachers College, D.C.

Total: 3

FLORIDA

Bethune-Cookman College, Daytona BeachFlorida A&M University, TallahasseeEdward Waters College, Jacksonville

State total: 3

GEORGIA

Albany State College, AlbanyAtlanta University, AtlantaFort Valley State College, Ft. ValleySavannah State College, SavannahPaine College, Augusta

State total: 5

HAWAII

University of Hawaii, HiloUniversity of Hawaii, Honolulu

State total: 2

ILLINOIS

Chicago State University, Chicago

State total: 1

KANSAS

Haikell Indian Jr. College, Lawrence

State total: 1

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APPENDIX II APPENDIX II

KENTUCKY

Kentucky State University, Frankfort

State total: 1

LOUISIANA

Dill 'rd University, New OrleansGrambling State University, GramblingSouthern University, Baton RougeSouthern University, New OrleansXavier University, New Orleans

State total: 5

MARYLAND

Coppin State College, BaltimoreUniversity of Maryland Eastern Shore, Princess AnneBowie State College, BowieMorgan State College, Baltimore

State total: 4

MISSISSIPPI

Alcorn State University, LormanJackson State University, JacksonMississippi Industrial College, Hoily SpringsRust College, Holly SpringsTougaloo College, TougalooMississippi Valley State College, Itta Bena

State total: 6

MISSOURI

Lincoln University, Jefferson City

State total: 1

MONTANA

Northern Cheyenne Tribe, Lame Deer

State total: 1

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APPENDIX II APPENDIX II

NEW MFXICO

University of Albuquerque, AlbuquerqueNew Mexico Highlands University, Las VegasNew Mexico State University, Las CrucesUniversity of New Mexico, AlbuquerqueCollege of Santa Fe, Santa Fe

State total: 5

NEW YOR'K

City University of New York, York College, JamaicaSeneca Health and Research Authority, Amberst

State total: 2

NORTH CAROLINA

Bennett College, GreensboroElizabeth City State University, Elizabeth CityJohnson C. Smith Uiversity, CharlotteNorth Carolina A&T State University, GreensboroNorth Carolina Central University, DurhamShaw University, RaleighWinston-Salem State University, Winston-SalemBarber-Scotia College, ConcordFayetteville State University, FayettevilleSaint Augustine's College, RaleighPembroke State University, PembrokeLivingstone College, Salisbury

State total: 12

NORTH DAKOTA

Turtle Mt. Counseling-Rehabilitation Center, Belcourt

State total: 1

OHIO

Central State University, WilberforceWilberforce University, Wilberforce

State total: 2

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APPENDIX II APPENDIX II

OKLAHOMA

Northeastern Oklahoma State University, TahlequahSoutheastern Oklahoma State University, DurantLangston University, Langston

State total: 3

PENNSYLVANIA

Lincoln University, Lincoln UniversityCheyney State College, Cheyney

State total: 2

PUERTO RICO

Catholic University, PonceUniversity of Puerto Rico, Rio PiedrasUniversity of Puerto Rico, MayaguezUniversity of Puerto Rico, San Juan

Total: 4

SOUTH CAROLINA

Benedict College, ColumbiaSouth Carolina State College, OrangeburgAlien University, ColumbiaVoorhees College, Denmark

State total: 4

TENNESSEE

Fisk University, NashvilleKnoxville College, KnoxvilleMeharry Medical College, NashvilleTennessee State University, NashvilleLane College, Jackson

State total: 5

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APPENDIX II APPENDIX II

TEXAS

Bishop College, DallasPan American University, EdinburgPrairie View A & M University, Prairie ViewTexas A&I University, KingsvilleTexas Southern University, HoustonUniversity of Texas, El PasoUnited Colleges of San Antonio, San AntonioHuston-Tillotson College, AustinTexas College, Tyler

State total: 9

VIRGINIA

Hampton Institute, HamptonNorfolk State College, NorfolkVirginia State College, PetersburgVirginia Union University, RichmondSaint Paul's College, Lawrenceville

State total: 5

VIRGIN ISLANDS

College of the Virgin Islands, Saint Thomas

Total: 1

TOTAL INSTITUTIONS: 104

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APPENDIX III APPENDIX III

LIST OF MBS APPLICATIONS RECOMMENDED FOR APPROVAL

BUT UNFUNDED AS OF JUNE 30, 1976

Number of Have anyapplications applications.

approved ever beeninfunded Name of institution funded?

ALABAMA

2 Alabama A & M University,Normal Yes

1 Miles College, Birmingham No1 Tuskegee Institute, Tuskegee Yes1 Talledega College, Talledega Yes

ARKANSAS

1 Philander Smith College,Little Rock No

ARIZONA

1 Navajo Health Authority,Window Rock No

CALIFORNIA

2 University of California,Santa Cruz Yes

1 University of California,van Diego Yes

1 Charles Drew Postgraduate MedicalSchool, Los Angeles Yes

1 California State University,Los Angeles Yes

FLORIDA

1 Bethune-Cookman College, DaytonaBeach Yes

1 Edward Waters College, Jacksonville No1 Florida A & M University,

Tallahassee Yes

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APPENDIX III APPENL'X III

Number of Have anyapplications applications

approved ever beenunfunded Name of institution funded?

GEORGIA

1 Fort Valley State College, FortValley Yes

1 Savannah State College, Savannah Yes

KANSAS

1 Haskell Indian Junior College,Lawrence Yes

KENTUCKY

1 Kentucky State University,Frankfort Yes

LOUISIANA

1 Xavier University, New Orleans Yes

MARYLAND

1 University of Maryland EasternShore, Princess Anne Yes

MISSISSIPPI

1 Rust College, Holly Springs Yes1 Mississippi Valley State College,

Itta Bena No1 Mississippi Industrial College,

Holly Springs Yes

NEW MEXICO

1 College of Santa Fe, Santa Fe No1 New Mexico State University,

Las Cruces Yes1 University of New Mexico,

Albuquerque Yes

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APPENDIX III APPENDIX III

Number of Have anyapplications applications

approved ever beenunfunded Name of institution funded?

NEW YORK

1 City University of New York, YorkCollege, Jamaica Yes

NORTH CAROLINA

1 Saint Augustine's College, Raleigh No1 Elizabeth City State University,

Elizabeth City Yes2 Livingstone College, Salisbury No1 Pembroke Sate University, Pembroke No

OHIO

1 Wilberforce University, Wilberforce No

OKLAHOMA

1 Langston University, Langston Yes1 Northeastern Oklahoma State

University, Tahlequah Yes

PENNSYLVANIA

1 Cheyney State College, Cheyney Yes2 Lincoln University, Lincoln

University Yes

SOUTH CAROLINA

1 South Carolina State College,Orangeburg Yes

TENNESSEE

2 Tennessee State University,Nashville Yes

1 Lane College, Jackson No1 Knoxville College, Knoxville Yes

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APPENDIX III APPENDIX III

Number of Have anyapplications applications

approved ever beenunfunded Name of institution funded?

TEXAS

1 Huston-Tillotson College, Austin No1 Texas A&I Universtiy, Kingsville Yes1 Prairie View A&M University,

Prairie View Yes1 United Colleges of San Antonio,

San Antonio Yes

VIRGINIA

1 Virginia State College, Petersburg Yes

PUERTO RICO

1 University of Puerto Rico, Mayaguez No1 University of Puerto Rico, San Juan Yes

VIRGIN ISLANDS

1 College of the Virgin Islands,St. Thomas Yes

TITAT INSTITUTIONS: 47

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APPENDIX IV APPENDIX IV

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APPENDIX V APPENDIX V

PRINCIPAL OFFICIALS RESPONSIBLE FOR

ACTIVITIES DISCUSSED IN THIS REPORT

Tenure of officeFrom To

SECRETARY OF HEALTH, EDUCATION,AND WELFARE:Joseph A. Califano Jan. 1977 PresentDavid Mathevs Aug. 1975 Jan. 1977Caspar W. Weinberger Feb. 1973 Aug. 1975Frank C. Cariucci (acting) Jan. 1973 Feb. 1973Elliot L. Richardson June 1970 Jan. 1973

ASSISTANT SECRETARY FOR HEALTH(note a):James F. Dickson III (acting) Jan. 1977 PresentTheodore Cooper (note b) Feb. 1975 Jan. 1977Charles C. Edwarc's Mar. 1973 Jan. 1975Richard L. Seggel (acting) Dec. 1972 Mar. 1973Merlin K. DuVal, r. July 1971 Dec. 1972

DIRECTOR, NATIONAL INSTITUTESOF HEALTH:

Donald S. Fredrickson July 1975 PresentR. W. Lamont-Havers (acting) Feb. 1975 July 1975Robert S. Stone May 1973 Jan. 1975John F. Sherman (acti.ng) Jan. 1973 May 1973Robert Q. Marston Sept. 1968 Jan. 1973

DIRECTOR, DIVISION OF RESEARCHRESOURCES:Thomas G. Bowery Nov. 1969 Present

a/Title of office was changed from Assistant Secretary forHealth and Scientific Affairs, Nov. 1972. Position createdNov. 1965.

b/Acting from Feb. 1975 until May 1975.

38