While NIH expects applications to be submitted by their deadlines, it may accept a late application and has recently announced a 2-week window of consideration for all types of applications. Beginning with applications due on or after January 25, NIH will consider accepting applications during this grace period provided a cover letter submitted with the application includes an appropriate justification for being late. The new policy includes submissions in response to most requests for applications and program announcements with special due dates. For exceptions, acceptable reasons and other details, see Simplifying the NIH Policy for Late Application Submission.
The annual Research Performance Progress Report (RPPR) is how we assess progress toward your funded project’s goals and whether your project is in compliance with guidelines set forth in the NIH Grants Policy Statement. The designated grants management specialist and program official (PO, also known as program director) review each progress report. After these staff members approve the report, we can issue a notice of award for the noncompeting continuation of the grant.
Typically, this administrative review is a straightforward process, but sometimes issues arise that can delay the processing of the award and create additional work for everyone involved. Here are some of the most common issues we encounter:
- Public access compliance: Before initiating the RPPR, you should enter all appropriate citations into your NCBI My Bibliography, associate them with the appropriate grant number and select the citations to include in this year’s RPPR. The RPPR software will then complete Section C.1 automatically. When noncompliant publications are identified, you should immediately begin (or complete) the process of bringing those publications into compliance.
- Publication reporting in the RPPR: List publications in Section C of the progress report, not in Section B.2, “What was accomplished…,” or elsewhere in the text. For more details, see Janna Wehrle’s post on Progress Reports and the Public Access Policy.
- Change in scope: A request for a change in project scope is a prior approval request that must be submitted by your Authorized Organizational Representative (AOR) and requires review by the grants management specialist and PO; this is done separately from the progress report review. Please remember that adding human subjects and/or vertebrate animals to a grant that previously did not have these activities is considered a change in scope.
- Discrepancies in answers to RPPR questions: Please double-check your responses to questions about the administrative aspects of your grant. Inconsistent answers to these questions often trigger a flurry of e-mails from us requesting clarification from the AOR and investigator. In my experience, the most common issues involve changes in other support, key personnel and vertebrate animal use, or they indicate a change when none exists.
- Description of collaborations: Please adequately describe how any collaborations contribute to the project. This is especially important for collaborations with foreign investigators and collaborations involving the sharing of samples from human subjects or vertebrate animals.
- Level of effort: Be sure to use whole numbers to report person-months of effort on a grant.
- New reporting requirements: Keep track of new reporting requirements, such as the new inclusion management system to report data on sex/gender, race and ethnicity in clinical research. Resources for staying up to date on such requirements are the NIH Guide and the Extramural Nexus blog.
Finally, your progress report should include a relatively brief description of the project’s scientific progress in the last funding period. We want to know what you think are your most impactful and exciting discoveries from the past year, as well as where the project is headed in the next funding period. Reading these descriptions is one of the most interesting parts of my job.
When in doubt on what to include in the progress report, contact your PO.
Jon Lorsch recently posted a message about the responsibility that our grantee community shares with us to help the research enterprise thrive. One way that we have addressed this is by taking a hard look at the funding of investigators who are already well supported. As most of you know, in an effort to increase efficiency and to support as many outstanding scientists as possible, we have long required special advisory council approval for any grant that, in combination with the principal investigator’s (PI’s) other research support, would provide over $750,000 in direct costs.
We have now developed guidelines that we will use in awarding R01s and other research grants to investigators with substantial levels of long-term, unrestricted research funding from any source. Unrestricted funding means that it is not project-based and may be used to conduct research on a broad topic at the PI’s discretion. We consider such support substantial and long-term if it is over $400,000 in direct costs (excluding the PI’s salary and direct support of widely shared institutional resources) and extends for at least 2 years from the time the NIGMS grant would be funded.
Abiding by these new guidelines will enable us to fund additional labs, increasing the likelihood of making significant scientific advances. The guidelines will take effect for applications submitted on or after January 2, 2016. If you might be affected by the new guidelines, I encourage you to discuss your plans with your program director.
The NIH Extramural Nexus blog has published posts on video resources that you may find helpful:
New Webinars Connect Applicants to NIH Peer Review Experts: The Center for Scientific Review is hosting webinars in early November to give R01, R15, SBIR/STTR and fellowship grant applicants and others useful insights into the submission and review processes. Register by October 28.
New Video Tutorials Can Help You Navigate eRA Commons: A 10-part series of short video tutorials walks you through the steps for submitting just-in-time information, a no-cost extension, a relinquishing statement and more. Watch the tutorials on the NIH Grants playlist on YouTube.
If you have an NIGMS research grant, we want to raise your “IDP consciousness.” If you’re unfamiliar with this abbreviation, IDP stands for “individual development plan.”
A recent NIH Guide notice announced a revised policy on describing the use of IDPs in annual progress reports that requires you to include a section on how you use IDPs to help identify and promote the career goals of the graduate students and postdocs supported by the grant. The notice states:
NIH will not require but strongly encourages institutions to develop and use IDPs for graduate students and postdoctoral researchers supported by NIH awards, regardless of their position title. IDPs provide a structure for the identification and achievement of career goals. Therefore, NIH encourages grantees to develop institutional policies that employ an IDP for every graduate student and postdoctoral researcher supported by NIH awards. Beginning on October 1, 2014, annual progress reports are required to include a description of whether the institution uses IDPs or not and how they are employed to help manage the training and career development of those individuals.
Please note that you should not include the actual IDPs in your progress report.
NIGMS’ training strategic plan emphasized the importance of IDPs, and our IDP Web page provides useful resources for preparing and implementing them. If you have other tips for using IDPs or meeting the new progress report requirement, please feel free to share them here.
NIH has just announced a significant change in its policy for resubmission applications.
Effective immediately, for application due dates after April 16, 2014, following an unsuccessful resubmission (A1) application, applicants may submit the same idea as a new (A0) application for the next appropriate due date. NIH will not assess the similarity of the science in the new (A0) application to any previously reviewed submission when accepting an application for review.
NIH’s policy for accepting overlapping applications remains in effect (see NOT-OD-09-100), so it will not accept duplicate or highly overlapping applications under review at the same time. This means that NIH will not review:
- A new (A0) application that is submitted before issuance of the summary statement from the review of an overlapping resubmission (A1) application.
- A resubmission (A1) application that is submitted before issuance of the summary statement from the review of the previous new (A0) application.
- An application that has substantial overlap with another application pending appeal of initial peer review (see NOT-OD-11-101).
The NIH time limit for accepting resubmission (A1) applications remains in effect, as well (see NOT-OD-12-128 and NOT-OD-10-140). NIH will not accept a resubmission (A1) application that is submitted later than 37 months after submission of the new (A0) application that it follows.
Also remaining in effect is the NIH policy for new investigator R01 resubmission deadlines, described in NOT-OD-11-057.
Each year, an average of 65 NIGMS-funded principal investigators move to new universities or other institutions. With everything else they need to do, they sometimes neglect to consider how the move will affect their grants, or they start the process too late. When they try to hire staff or purchase supplies in the new location, they may discover that grant funds are not available. Remember that your grant is made to an institution, so you will need to involve your current and your new institutions early on to make sure that your transition is smooth.
You also need to be in touch with NIGMS staff early, allowing enough time for us to review any move-related change that requires NIH approval and, if approved, process it. When you begin plans to change institutions, contact your NIGMS program director and grants management specialist to discuss the timing of your move, options for managing your grant through the transition and the possible impact of the transfer on your research. Some situations don’t require the transfer of your grant at all. NIGMS staff can help you find the right solution for your circumstances, including the management of consortium arrangements and the involvement of animals or human subjects.
If you do want to transfer a grant to a new organization, you should contact NIGMS staff well before the anticipated start date at the new institution. Both your former institution and your new one will need to submit information to us before the grant can be moved and you can draw funds. We recommend providing all required materials at least 3 months in advance of the move.
Here are some NIH resources on transferring grants:
PA-14-078 Change of Grantee Institution (Type 7 Parent)
NIH Grants Policy Statement, Section 184.108.40.206 Change of Grantee Organization
NIH’s Sally Rockey recently blogged about SciENcv, a new tool for easily generating and maintaining biosketches for federal grant applications and progress reports. The system also allows users to link biographical information with publication records and to generate a unique international ID through the ORCID initiative.
SciENcv is presently in beta release. Users—from seasoned investigators creating biosketches for different grant applications to students and postdocs writing a biosketch for the first time—can provide feedback about what works, what doesn’t and what other functionalities they want. Register for SciENcv via MyNCBI, and send your input by using the site’s contact form or by e-mailing email@example.com.
One of the biggest challenges facing NIH after the government shutdown is that it occurred during a peak review period and caused the cancellation of several hundred peer review meetings. On October 22, NIH announced that most of these meetings would be rescheduled so as to minimize the disruption of the submission/review/Council/award timeline.
While NIH may not be able to preserve the timeline for all applications, at this point, it looks as though most will still go to January 2014 council meetings. More details are available in a new NIH Guide notice.
Most of the study sections run by the NIGMS Office of Scientific Review were not affected by the shutdown and will proceed as planned over the next few weeks. While a few meetings will have to be rescheduled, we expect the results of the rescheduled meetings to be available in time for our January council meeting.
The other big challenge facing NIH and the extramural community is the disruption in the application process, since funding opportunity announcements (FOAs) could not be accessed and applications could not be submitted during the shutdown. NIH has rescheduled the submission dates that were lost and extended the dates for those FOAs that were adversely affected. More details are available in the same NIH Guide notice.
Sally Rockey’s blog provides more on NIH’s efforts to minimize the disruption of the shutdown’s effects on the extramural community.
Following on from my earlier post, Progress Reports and the Public Access Policy, I’d like to share answers to a few of the questions program directors/principal investigators (PDs/PIs) have asked about compliance procedures.
I didn’t submit my paper to PubMed Central until recently and my progress report is due. They tell me it may take 6 weeks to complete the process. What should I do?
Respond promptly when the NIH Manuscript Submission System (NIHMS) requests that you approve the version to be posted so your PMCID can be issued as quickly as possible. Also, check with your sponsored projects or research administration office about procedures during a possible gap in funding.
The public access policy requires papers to be submitted to the NIHMS upon acceptance for publication. Because so many PDs/PIs are still catching up on submitting their publications, PubMed Central processing times are much longer than the usual 2 weeks. As NIH announced in February, noncompeting continuation awards will not be made until publications arising from that grant are in compliance with the NIH Public Access Policy.
The law mandating the Public Access compliance requirement is based on the use of grant funds for published research. When in doubt about publication-grant associations, contact your NIH program official (PO).
Should I report ALL my grant’s publications in my annual progress report?
No. Just report the publications arising from this grant’s funding during the single grant year you’re reporting.
Even if they have only recently been added to your NCBI My Bibliography, don’t include publications from previous grant years. You should still make sure the earlier publications have PMCIDs, because it’s the law and a legal term and condition of your NIH award. In addition, you’ll need PMCIDs for competing renewal applications and NIH biosketches.
I inadvertently assigned a publication to my RPPR that describes work not funded by the grant being reported. What can I do?
If you realize this BEFORE the RPPR (or PHS 2590) is submitted to NIH by your sponsored projects or research administration office, you can remove the link in the My Bibliography Award View display by unchecking the box. (Yet another reason to run the Public Access Compliance report early: Making corrections is easy!)
A lock icon indicates that a publication-grant connection has already been recorded. A yellow lock means the paper was linked to the award in the NIHMS. To undo this association, you’ll need to contact the NIHMS Help Desk. A gray lock means the paper has already been officially reported to NIH as arising from the award. To undo that association, you’ll have to officially amend the report that triggered the lock. Please contact the NIH PO for the grant. If your PO approves the correction, ask him or her to e-mail PublicAccess@mail.nih.gov to execute the change.
I thought the journal’s publisher would submit my paper for me. Why is the citation marked “noncompliant”?
The NIH Public Access Web site describes the four submission methods (A, B, C and D) and lists for each method what the publisher will do, what an author must do and what a designee can help with. Different publishers, and even different journals from the same publisher, follow different practices. The key is for you and any other authors to understand which method you and your publisher have agreed to. Perhaps the most common issues are:
- An author expects a Method B publisher to complete the entire compliance process without having made a specific arrangement with the publisher.
- An author (or designee) submits the final, peer-reviewed manuscript directly to the NIHMS (Method C) or a Method D publisher submits the manuscript, but one of the authors does not follow through to:
- Authorize the NIHMS to process the manuscript to PMC format (a quick return e-mail), and
- Approve the formatted version to be posted on PubMed Central.
All authors should agree on who will do the various steps. And it’s a good idea to have a back-up plan.
My paper was published as an open access article. Why do I need a PMCID?
Journals and publishers are free to change their access policies at any time or to remove papers that have been posted. NIH is required by law to assure that papers describing work funded by our grants are and remain available to the public through PubMed Central.
What if I have other questions?