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Science Careers Blog

October 8, 2008

Two Strikes, You're Out at NIH

The National Institutes of Health announced this morning that starting after the 25 January 2009 submission date, NIH will begin considering ONLY ONE RESUBMISSION. After that, a proposal will be regarded as new and assigned a new number. Second "amendments" will no longer be considered.

Reportedly, NIH has been considering a move like this--initially the proposal was to eliminate resubmissions entirely--for some time now. The thinking, I believe is that reviewers and study-section members may feel an obligation to reward investigators who have jumped through the reviewer's hoops enough times. That kind of thinking can lead to the funding of proposals that hang around long enough (a lot like awarding Ph.D.s to certain graduate students we've all known)--that is, it can lead to more conservative funding decisions. People were also concerned that many proposals were being funded only on resubmission, delaying the awarding of a grant (and the subsequent research), and increasing the burden on reviewers and study-section members who have to review a proposal several times.

The new policy is comprehensive, covering all proposals that currently allow resubmissions: NIH Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs, Career Development Awards, Individual Fellowships, Institutional Training Grants, Resource Grants, Program Projects, and Centers.   

Here's the NIH announcement, in full:

New NIH Policy on Resubmission (Amended) Applications
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Notice Number: NOT-OD-09-003

Key Dates
Release Date:  October 8, 2008

Issued by
National Institutes of Health (NIH), (http://www.nih.gov)

Purpose

NIH announces a change in the existing policy on resubmission (amended)
applications (see http://grants.nih.gov/grants/policy/amendedapps.htm). Beginning with original new applications (i.e., never submitted) and competing renewal applications submitted for the January 25, 2009 due dates and beyond, the NIH will accept only a single amendment to the original application.  Failure to receive funding after two submissions (i.e., the original and the single amendment) will mean that the applicant should substantially re-design the project rather than simply change the application in response to previous reviews.  It is expected that this policy will lead to funding high quality applications earlier, with fewer resubmissions.

Background

Following the release of the Peer Review Report that was drafted with extensive consultation with the external community, Dr. Zerhouni, NIH Director, established a Peer Review Oversight Committee (PROC) to finalize the recommendations and begin immediate implementation of those recommendations.  Of particular concern was the marked reduction in the number of awards made in response to original applications.  An increasing number of projects were funded only after one or more resubmissions.   In
periods of constricted funding, a greater number of projects require resubmission, and review committees are more likely to show greater preference for amended applications.  These trends have increased the time from original submission to award and the number of submissions per
investigator. As a result, there has been greater burden placed on applicants and reviewers as well as a delay in funding for meritorious science.

To change this trend and increase the likelihood that meritorious original applications will be funded, the NIH will decrease the number of amendments allowed.  Accordingly, the NIH will begin to phase out second amendment applications starting with the January 25, 2009 due date. This policy will increase the numbers of high quality original and first amendments that can be funded earlier.

NIH Policy on Resubmission (Amended) Applications

Beginning with applications intended for the January 25, 2009 due date, all original new applications (i.e., never submitted) and competing renewal applications will be permitted only a single amendment (A1).  For this and subsequent cohorts of original new and competing renewal applications, any second amendment (A2) will be administratively withdrawn and not accepted for review.   Applicants who fail to receive funding after two submissions may resubmit but only if the application is fundamentally revised to qualify as new.  A new application is expected to be substantially different in content and scope with more significant differences than are normally encountered in an amended application.  Note that there is no time limit for the submission of the original and subsequent A1.

Original new and competing renewal applications that were submitted prior to January 25, 2009 will be permitted two amendments (A1 and A2).  For these "grandfathered" applications, NIH expects that any A2 will be submitted no later than January 7, 2011, and NIH will not accept A2 applications after
that date.

This policy applies to all applications, including applications submitted under the NIH Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs, Career Development Awards, Individual Fellowships, Institutional Training Grants, Resource Grants, Program Projects, and Centers.  Currently no amendments are permitted for applications received in response to a Request for Applications (RFA) unless it is specified in the Funding Opportunity Announcement, in which case only
one amendment will be permitted.  ations (RFA) unless it is specified in the Funding Opportunity Announcement, in which case only one amendment will be permitted.

Inquiries
Applicants are strongly encouraged to discuss their questions with their NIH IC contact.  For additional information or questions, please contact:

Division of Receipt and Referral
Center for Scientific Review
6701 Rockledge Drive MSC 7720
Bethesda, MD  20892-7720
Voice:  (301) 435-0715
Fax:  (301) 480-1987

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