Sheehy is a member of the Grants Working Group and has participated in the reviews of hundreds of grant applications at CIRM. He has served as its acting vice chairman on a number of occasions. Here is the text of his comments.
"I think we have gotten into a muddle over the question of appeals by applicants to CIRM and the ICOC(CIRM's board of directors). First, as Don Gibbons has reiterated in this item, objective process complaints such as one involving potential undisclosed conflicts of interest by reviewers are allowed by CIRM and given appropriate consideration with appropriate action if needed.
"However, appeals/comments concerning the content of reviews cannot be considered by CIRM staff. To do so would make CIRM staff effectively reviewers. In addition, CIRM staff could be placed in the position of making decisions regarding the funding of grant applications. Prop. 71 clearly gives the Grants Working Group (GWG) responsibility for reviewing grants and the ICOC takes those reviews as advice and then is solely empowered to make decisions to approve or not approve a grant application.
"CIRM and the ICOC could decide to implement a resubmission process allowing applications with disputed reviews to be re-reviewed by the GWG. I personally am undecided on this approach but think it is unlikely to be adopted.
"What is confusing is that appeals/comments about any item under consideration by the ICOC are expressly allowed. California public meeting laws govern a state agency with a decision-making board that meets in public. That means public comments/appeals are expressly allowed, as the ICOC has already experienced. In addition, letters to the ICOC regarding applications or any matter under consideration are also allowed and we have received them on an application and other matters.
"Instead of obfuscating and stonewalling, CIRM should be direct and forthright about this existing appeal process. In that context, the process could then be properly organized. Those who wish to use public comment can be informed of our current 3-minute limit and advised that the limit could be shortened to 2 or even 1 minute if we get a significant number of individuals who wish to comment. In addition, we could suggest length (hopefully a couple of pages) and format for written appeals (i.e., formats easy to post on CIRM¹s website). We could also inform applicants who wish to use this process that their letters will be made public and the application score and identity will be revealed upon receipt/posting of letters or after public comment.
"From my perspective, written comments/appeals from applicants would be preferable and I would hope to receive them early enough to consider thoughtfully as I review materials prior to ICOC meetings.
"Part of the rationale for the composition of the ICOC is to have on hand scientific expertise to inform decisions around grant applications. I have confidence that my colleagues can digest any additional input from applicants and make appropriate decisions. After all, the ICOC has already considered and made decisions regarding applications appealed to it."
Jeff Sheehy's thoughtful suggestions go a long way toward solving the problem of no formal appeals process for grant applicants.
ReplyDeleteThe problem so far has been that some disappointed applicants have sent letters or have appeared. Others have not, probably not realizing that they could.
Reminding applicants that they have the right to address the ICOC in person or by letter and offering guidelines on how to do so will benefit everyone.
Posting any letters well before a meeting will ensure that the process is completely transparent.
John M. Simpson
Stem Cell Project Director
Consumer Watchdog