Trying to navigate changes in NIH grant application policy can be a daunting task. Moreover, when these policy changes bypass the radar of applicants, the result can be an unwelcome outcome. This was the case most recently for many grant applicants who did not follow the new NIH policy limiting the types of appendix materials allowed for applications with due dates on or after January 25, 2017. This policy was first advertised last August to allow sufficient time for applicants to absorb the change. Unfortunately, many of the grant applications assigned to NIGMS came in for the January 25 receipt date with non-compliant appendix materials, resulting in their withdrawal by NIH. We at NIGMS are very aware of the pain and frustration felt by applicants and institutional authorized officials when applications are withdrawn. In the hope of minimizing the number of withdrawals due to non-compliant appendices for upcoming receipt dates, here are some important reminders:
- Under the new policy, almost nothing is allowed as appendix material unless specifically requested in the funding opportunity announcement (FOA).
- The few remaining materials that are still allowed are very specialized and do not apply to most FOAs.
- If the FOA you apply for is one that does allow or specifically requests certain types of appendix materials, be sure to include only what is allowed. If you include any additional materials, your application will be considered non-compliant and will almost certainly be withdrawn.
- Do not use application sections that have unrestricted page limits (e.g., the Other Attachments section) as a surrogate location for appendix materials that are no longer allowed because this also will result in your application being withdrawn as non-compliant.
- Lastly, be sure you are reading the most up-to-date versions of the FOA and SF424 instructions, as the materials that are and are not allowed in an application may have changed from previous versions.
One of the best resources to help you stay on top of new and upcoming changes is the Notices of NIH Policy Changes on the Office of Extramural Research website—please check this site frequently. And, as always, NIGMS program and review staff are available to answer any questions.
Given the challenges we all face with keeping up with all the regulations, why can’t NIGMS (or NIH) just delete the non-compliant materials and have the proposal reviewed? I don’t know what most of the non-compliant material was, but given the time between submission and review the investigator now faces a 4-6 months delay
The mechanism for enforcement of this new policy is draconian and punitive, and I am at a loss to understand how the goal of this policy aligns with the enforcement approach. In the case of NIGMS post-doctoral training grants, the consequences of non-compliance are a one year “time out” before re-submission of a withdrawn application (there is only one date per year for acceptance of these applications) and potential loss of funding of the same duration. Also, the financial impact in this case affects trainees who are entirely uninvolved with the grant submission process.
A more reasonable implementation approach would be to give those who submit applications with non-compliant appendices a choice: either withdraw the application or allow NIH to simply remove the non-compliant materials from the application, allowing the now compliant application to be reviewed.