Comment Letter

COGR's Response to Request for Information (RFI): Re-envisioning U.S. Postdoctoral Research Training and Career Progression within the Biomedical Research Enterprise [NOT-OD-23-084]

The Council on Governmental Relations (COGR), representing more than 200 U.S. research universities and affiliated institutions, submitted this response to the NIH’s Request for Information regarding the enhancement of postdoctoral research training and career progression in the biomedical field. COGR’s comments focus on several key policy areas to improve postdoctoral training pathways. It recommends increasing or eliminating the modular budget cap, currently at $250,000, to better support research activities such as mentoring and the funding of multiple trainees, as the reduced flexibility under the current cap hampers research support amid rising costs. COGR also supports raising the National Research Service Award (NRSA) stipend levels to better reflect the cost of living and market conditions, arguing that current stipend rates are inadequate for recruiting and retaining talented postdoctoral researchers.

Additionally, COGR highlights the need for more equitable benefits for NRSA fellows, noting that compensation is provided as stipends rather than salaries, leading to tax and benefit disadvantages and insufficient recognition of postdocs’ professional contributions. The council urges the NIH to engage with stakeholders to reconsider how postdoctoral positions are classified and compensated to address these disparities. Lastly, COGR calls for a reevaluation of long-standing NRSA policies, many of which have remained largely unchanged since the 1970s, advocating for clarifications and revisions that would reduce administrative burdens for postdocs, mentors, and institutions while better aligning policies with contemporary research needs and workforce expectations.

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