Category: Research Administration

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?

Contact your PO, e-mail PublicAccess@mail.nih.gov and/or visit the NIH Public Access Policy Web site.

As NIH announced in February, it will delay the processing of noncompeting continuation awards with budget start dates of July 1, 2013, and beyond if publications arising from that award are not in compliance with the NIH Public Access Policy.

Whether your award requires progress reporting in the new RPPR format (all SNAP-eligible and fellowship awards) or still uses the PHS 2590 progress report (you know who you are…), you must use My NCBI’s My Bibliography feature to identify and associate publications with the correct grant number(s). Changes to My Bibliography have improved the workflow and communication between PIs and non-PI authors, so it’s now easier for you to track compliance of all papers arising from your awards, even those for which you’re not an author. This YouTube video  provides a step-by-step demonstration of the whole process.

The RPPR module in the eRA Commons will automatically create the “C.1 Publications” list for your RPPR progress report, complete with NIH Public Access Compliance indicators, based on the grant affiliations in your My Bibliography account. For PHS 2590 progress reports, you will need to run the My Bibliography compliance report yourself, print the file and add it to your PHS 2590.

You can run the Public Access Compliance report in My Bibliography at any time, so there’s no need to wait ’til your progress report is due to check that all your publications are compliant and are affiliated with the correct grants.

If you are preparing a grant or fellowship progress report for a due date in May or after, you will need to use the Research Performance Progress Report (RPPR) for submission. For more information on this new requirement, see NOT-OD-13-035 and RPPR instruction guides, points of contact and background information.

NIH has recently updated its policy on what materials can be accepted after an application has been submitted but before initial peer review. Here are the changes:

1. News of a promotion or positive tenure decision will be accepted if received at least 30 calendar days prior to the review meeting and if confirmed by the authorized organization representative;
2. Exceptions that previously applied only to requests for applications (RFAs) with a single submission date now apply to the last due date of RFAs with multiple submission deadlines; and
3. Some specific types of personnel information associated with institutional training and training-related grants will now be accepted.

See NOT-OD-10-115 for all other requirements and exceptions.

The study section gave your application a competitive score, and now you’ve been asked to submit Just-in-Time (JIT) information about your other sources of funding, including active and pending support for key personnel on the application. Why do we request this information?

First, for all applications that might be funded, we check the JIT information for scientific overlap with the investigators’ active grants from NIH and other funding sources, since we can’t provide support for a project that’s already being funded.

Second, as directed by the NIGMS Advisory Council, we give additional scrutiny to new and competing renewal applications from investigators whose total research support, including the pending award, exceeds $750,000 or more in annual direct costs. These applications require special analysis and documentation from NIGMS staff to justify why the project is highly meritorious, and they are discussed by the Advisory Council.

Finally, we may use the information about other research support to decide which grants to recommend for funding and to establish the budget level of the award. As you may know, NIGMS does not rely solely on a percentile cutoff or “payline” to make funding decisions. We also consider other factors, including career stage, perceived impact of the proposed work, summary statement comments and the other funding available to the investigator.

I hope this post helps provide some context for how we use JIT information and why it is important that your JIT information is complete, accurate and submitted promptly after the request so as not to delay the funding decision. Additional JIT information is available on the NIH and NIGMS Web sites and from your program director.

Since 2008, NIH has required as a condition of all grant awards and cooperative agreements that scientists make their findings publicly accessible through the widely used PubMed Central repository. To increase the number of papers available to the public, NIH has announced that it will delay the processing of noncompeting renewals whose publications are not in compliance with this public access policy. The change will take effect as early as spring 2013, and it will coincide with the required use of the Research Performance Progress Report (RPPR) for SNAP and fellowship awards.

For more discussion on this topic, including how to ensure you meet the policy requirements, read Improving Public Access to Research Results written by NIH’s Sally Rockey.

Over the years, NIH has tried various approaches to make sure advisory council and institute or center (IC) staff members have all the information they need about applications being considered for funding. In March 2012, NIH announced the latest procedures for submission of this “just-in-time” (JIT) information:

1. All JIT information must be submitted via the NIH Commons.
2. The JIT function button will be activated for all scored applications, just in case it’s needed. This is neither an indication that you should submit JIT information nor an indication of your application’s likelihood of funding.
3. If your application has an impact score between 1 and 40, you will receive an automated e-mail, which only tells you to follow the JIT guidelines of the application’s corresponding NIH IC. Receiving this message does not necessarily indicate that you will need to submit JIT information, as noted in the NIGMS guidelines below.

You can find guidelines for most NIGMS applications on the Summary Statement and JIT Actions for Applicants Web page and in the relevant section of the funding opportunity announcement you’re responding to. Our current guidance is:

If your application, with the exception of T32 or R25 applications, received a percentile ranking between 1 and 20, or if a percentile ranking is not specified and the priority score is between 10 and 30, please submit Other Support information within 2 weeks of the availability of the Summary Statement. In addition, if your research involves vertebrate animals or human subjects, you must submit information as described in the above referenced Actions on Applications after Initial Review sheet for instructions on completing this information.

Should there be changes to this guidance, they will be reflected on the Web page, so I encourage you to check it each time you receive a summary statement. We’ve also posted JIT details for Training, Workforce Development, and Diversity grants, fellowships and SCORE grants. If your application’s grant mechanism isn’t covered, please consult the program contact listed on your summary statement for instructions.

In the future, we plan to cover what goes in the “Other Support” document and why we ask for it.