Where to put your Preliminary Data in the new 12-page NIH grant application

One of the biggest changes that has emerged in my grant writing since the NIH R01 application was dropped from 25 to 12 pages (for the meat of the proposal) and restructured has been the way that I present my preliminary data. A recent exchange with @superkash reminded me that I’ve never brought this up on the blog and as usual, I’m curious as to how my readers are approaching this situation.
Under the old format, there was a specific section for Preliminary Data (or a Progress Report for competing continuation applications). In fact it was one of the three major ones (Background and Significance and Research Plan were the other two). With the restructuring, this evaporated. The three major sections are now Significance, Innovation and Approach.
So where are the preliminary data supposed to go?

The original Notice announcing the restructuring recommended putting it in the Approach.

The Approach sub-section will include both Preliminary Studies for New Applications and Progress Report for Renewal/Revision Applications.

However in trying to create grant proposals that made sense to me (admittedly, biased by my experience in the old format) with the new 12 page limits, I found this wasn’t working. The overall push in restructuring the application is to force the PI to get to the point as quickly as possible, to show the reviewers why the proposal is so great and to concentrate on the big picture. Since showing some data is a quick route to revving up the reviewers’ engines, why leave it until late in the application?
It is also the case that many of my grant proposal ideas, at this stage of my career, are extensions of work that we have been involved with for quite a while. So the “Significance” part leans towards those types of significance that are related to ongoing work in the field and my laboratory and therefore Preliminary Data can be highly illustrative of the significance factor. So goes my thinking anyway. I’ve been putting figures as early as the first page of this section.
Innovation? Well, if you are proposing methods that qualify as innovative, this is an area where Preliminary Data are traditionally necessary to give some indication that your grand plan is going to work out. So there is often an argument for placing a figure or two in this section as well.
Now, since I’ve placed Preliminary Data in two of the major sections, no reason to hold back on the third, right? Sometimes there are figures that are too specific for background and too workaday for Innovation…but boy do they help to skip past any questions about why you selected one set of proposed conditions, controls or experiments rather than others in your Approach to the Specific Aims. So I’ve found myself sprinkling a figure or three well down into the specific parts of my experimental plan.
So is this kosher? Well, sure. Heck, I have run across PIs who did this with their proposals even back in the old days. Perhaps I was simply too conservative before and I should have been doing this all along. Live and learn. At any rate, the current advice from NIAID has this to say about Preliminary Data:

You can either include this as a subsection of Approach or integrate it into any of the three main sections.

So that confirms that there is nothing forbidden about this practice.
My longer term and/or more astute readers will have deduced by now that I am no longer serving an appointed term on a study section. So unfortunately I can’t deliver up any general impressions of how other people are handling their Preliminary Data sections. In lieu of that, perhaps my grant-writing readers will supply their thinking in the comments?
As a final thought, even though we are several rounds into the process this is still relatively early days. Reviewers don’t know what to expect and I assume are seeing a variety of responses to the revised format. It strikes me that this is a time during which your chances of paying a price for violating the grant format expectations of a study section is pretty low. That makes it a good time to be a little bit creative and see what works best to communicate your ideas and your science.
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p.s. Happy New Year of Grant Writing and Science Doing!