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The Honorable Tommy Thompson
Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, DC 20201

Dear Secretary Thompson:

We are writing on behalf of the American Geriatrics Society (AGS), an organization of over 6,000 geriatricians, health care professionals, and basic and clinical researchers specializing in aging regarding initiatives that would negatively impact the research being conducted under the auspices of the National Institutes of Health (NIH).

We view the NIH as the world's premier science research funding organization and wish to see it continue flourishing. In this regard, the AGS is concerned about two initiatives that may seriously affect research conducted by the NIH: (1) the Office of Management and Budget's (OMB) competitive outsourcing plan; and (2) efforts to consolidate and centralize many functions, such as grants management, budget and acquisitions at NIH.

First, we believe that the competitive outsourcing plan described in OMB Circular A-76 would undermine the NIH's peer review and scientific program-management processes. According to Circular A-76, agencies must classify jobs as being "inherently governmental" or "commercial". Commercial positions will be put up for competitive bidding in the private sector, while inherently governmental positions will remain within the public sector. While the majority of the positions that may be subjected to competitive outsourcing are clerical, some of them, specifically those related to the peer review and grants management processes, are filled by highly trained PhDs with specific skills essential to the scientific work of the agency: scientific review administrators (SRAs) and health scientist administrators (HSAs).

NIH's success is in part attributable to these SRAs and HSAs. SRAs and HSAs play a unique and essential role in overseeing the review, allocation and administration of research resources. Each SRA and HSA brings with them the scientific expertise and judgment required to understand and assess the detailed scientific review process. It can take years to amass a thorough knowledge of a scientific area, thus necessitating the need for continuity of SRAs and HSAs. Their skills and objectivity cannot be replaced by those of contract employees from private companies.

We understand these intramural positions have been classified provisionally by NIH as "inherently governmental" and are not in danger of being outsourced for fiscal year (FY) 2004, but that a re-evaluation of the situation will take place next year. The Department of Health and Human Services (HHS) may decide to override NIH's classification of SRAs and HSAs as inherently governmental for FY 2005, thus endangering the research process and the realization of the NIH mission to improve the nation's health. We support NIH's current classification of SRAs and HSAs as inherently governmental and hope that HHS also continues to support NIH's decision.

Second, we are concerned about proposed consolidation and centralization efforts proposed in a 2003 memo on "Controlling FTE Growth in HHS". Steps discussed, such as hiring freezes and reduction of positions, are incompatible with effective management of the increased funds made available to NIH through the recent doubling of the budget. We fear such steps would jeopardize NIH's ability to realize the scientific research progress that the doubling was intended to support.

Centralizing personnel functions from individual institutes and from the NIH Director's office to make them report directly to the HHS, as is already underway, has had the effect of slowing down the hiring process and making it more difficult for NIH managers to play an appropriate role in personnel decision and actions. Furthermore, consolidating administrative functions is more likely to cause severe disruptions of basic management processes and functions at NIH. We ask that you revisit these changes.

Thank you for considering the concerns of the American Geriatrics Society. If you should have comments or questions on this letter, please contact Susan Emmer in our Washington office at 301-320-3873.

With kind regards,

Richard W. Besdine, MD, FACP, AGSF
President
American Geriatrics Society