Extensive guidance from NIH on Unallowable Resubmissions of Grant Applications

As we’ve discussed before, the change to permit only a single revision of a NIH grant has thrown a lot of uncertainty into the extramural research force. Although one obvious solution would be to just submit another “new” grant that is a thinly disguised re-working of the prior unfunded version, the CSR of the NIH is on to us. They have been working diligently to convince us that they will weed out such dodges with extreme prejudice.
I have just noticed that they have an extensive description of their screening process up on a web page. Complete with some examples and scenarios.
Key things that caught my eye include:

Which Applications Are Problems?
· Applications submitted as new (A0) but appear to be resubmissions (A1)

Yikes. So even if you get triaged and have criterion scores in the 7s and 8s, you can’t just start over with an A0? The decision isn’t up to you. You have to resubmit.
More after the jump…

When we compare applications, we examine all parts, particularly the Specific Aims and Research Strategy sections using text comparison software and the expertise of those mentioned above. Subsequent versions of an application may be quite different and are still considered to be overlapping if many of the hypotheses, aims, and/or outcome measures are the same or highly similar–particularly when the “new” application is responsive to the critiques of another application.

emphasis added.
Geez! text comparison software? This is BS! I wouldn’t be surprised in the least if I 1) have stylistic elements to my writing that don’t change much and 2) have grantsmithing habits that I deploy explicitly because they seem to have been successful in prior grant reviews. Not to mention I freely suggest phrasing to my colleagues who are looking for grantsmithing advice.
The last bit makes me go…hmmmmm. I mean this is pouring salt in the wound. I have the distinct impression that to whatever degree my grantsmithing has improved generally over the years, it is in no small part due to being “responsive to the critiques of another application”. I mean seriously. You have a study section harp on about five specific issues….you are going to tend to have other ideas that go to that study section….and you aren’t going to apply what you learned so painfully with the last go-round to your current proposal? Gaah! (As always, a particular little stiff-arm to the newbs.)

Examples of Changes that Could be Substantial
* Changing the disease model

Brings up some interesting implications for those of us in the substance abuse fields, does it not? Alcohol and “all other drugs” currently enjoy the distinction of different ICs. Pretty clear evidence of being a different “disease model”, right? Yet many of our colleagues work on showing the similarities of the addiction process, regardless of the drug of choice (including Alcohol). Much of this understanding is powering the upcoming merger of NIAAA and NIDA into one Institute. Even within NIDA’s current portfolio, different drugs could be seen as different “disease models”. Are they? Sufficiently different I mean? Are two different viral infections different? Two closely related bacterial infections? How different do the cancers have to be to constitute a different “disease model”?
Grrr.
You are allowed to contest the rejection of your application.

The Arbitration Board is consulted if an applicant rebuts the previous decision to the CSR Director. This board includes 12 scientific staff from across NIH, meets once a week and adds additional consistency to decisions. No members of the Scientific Overlap Committee or Division of Receipt and Referral staff serve on this board. CSR’s Director finalizes the decision of this board and communicates the result to the applicant. The Division of Receipt and Referral takes action as needed.

hahah, excuse me if I don’t fall all over myself believing this process will be that useful. As with any other situation in which PIs wish to appeal NIH decision making, my assumption is that there is no real motivation for NIH to do anything other than stonewall.
One last interesting bit:

NIH now has a 37-month limit for resubmissions. If you do not submit an A1 version of your application within the 37 months of your initial submission or if your A1 is not successful by the end of this period, a future application you submit on the same general topic will be considered a new application. Given the pace of scientific discovery, NIH would expect this application to manifest substantial changes in its scope and approach.

Yay! If you can just hang on for three years, you can try again. lolsob, as the kids say, lolsob.
I do like the fact that it is tied to the original submission because what this really means is a much shorter timeline. Say your original went in this round, Feb 5, 2011. Reviewed in Jun/Jul. Say your summary statement comes out in time for you to get your revised application in by Nov 2011. You will know your dismal fate one year after original submission and your next possible submission date would have been 17 months on. Realistically, however, we should insert an extra round in between the first two versions. Assuming additional data have been requested, teaching loads, etc. Its a good bet that reality will have you pushing it back to a Mar 2012 resubmission of the A1, review in Jun/Jul 2012. When that review disappoints, you’d be looking at Oct 5, 2012 as your next available new grant date. This is a 21 month timeline. When you look at it that way, they are only (“only”) inserting another 16 months delay. Sounds better than 37 months anyway*.
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*hey, I’m trying to look at the bright side here 😦