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Special scrutiny for PIs who hold $1 Million in NIH Grant funds

Well that was fast. Quick on the heels of the pilot study conducted for the summer Council rounds, the NIH issued NOT-OD-12-140.

In September 2012, NIH will be implementing a general policy whereby Advisory Council members will provide additional consideration of new and renewal applications from well-supported investigators who currently receive $1 million or more in direct costs of NIH funding to support Research Project Grants (RPG). RPG for the purposes of this policy is defined as: R00, R01, R03, R15, R18, R21, R22, R23, R29, R33, R34, R35, R36, R37, R55, R56, RC1, RC2, RC3, RC4, RL1, RL2, P01, P42, UA5, UC1, UC2, UC4, UH2, UH3, UM1, U01, U19, U34, DP1, DP2, DP3, DP4, and DP5. These RPGs are generally investigator-initiated research projects rather than NIH’s other grant programs which include support for investigator training and development and center grants.

One key change is that the scrutiny will be triggered by $1M in direct costs rather than the $1.5M in total costs which was used for the pilot study. As I said in my prior post:

The threshold of $1.5 million total costs. How’s that break down? Well if you are in a consensus ~50% overhead state university, let’s see…Thats FOUR full-modular awards. But let’s be clear, odds are you got cut by at least a module per award so that’s only $900K direct..you get to be in a University with about 70% overhead and you are still clear. What bout the much-rumored 100% overhead small institutions? well, you get three R01s before you go under strict scrutiny.

Moving it to direct costs makes it fairer to the individual PI; being at a high versus a low overhead institution or University does not affect the trigger.

This is not going to affect all that many applications. This policy means the PI will have to have 4 concurrent full-modular R01s before the special scrutiny is triggered. As we’ve seen from data posted on Rock Talk, in FY2009 7% of investigators had 3 or more Research Project Grants and 1.5% had 4 or more.

There are also key exceptions to the $1M rule that will further decrease the number of scrutinies.

• Pending applications submitted in response to Requests for Applications (RFA), which use a single round of competition to address a targeted research objective of IC(s) and are separately considered for funding.
• P01s and other multi-project RPG applications unless all of the PD/PIs and sub-project leaders are at or above the $1 million threshold.
• Multi-PD/PI projects unless all of the PD/PIs are at or above the $1 million threshold.
• Subprojects within complex applications. This may be revisited by NIH once we begin to accept complex applications through eRA Commons.
• Administrative supplements

Naturally, the BSDs who are in the 1.5% of NIH-funded investigators will already be pursuing RFAs, large-mechanism awards like Program Projects (P01) and Centers and other “complex” applications. They will already, for grantspersonship, practical and scientific reasons be including more-junior (read, less well-funded) investigators as the occasional component or Core PI. They may similarly be pursuing Multi-PI awards. All of this means that very few applications are going to be receiving this special scrutiny.

And do remember, people, that scrutiny means only that. It only means that Advisory Councils will have to briefly consider the arguments for the application receiving funding. And in an era in which awards need to be in the top 10%, maybe 12% to be shoo-ins for funding…do you really think the Councils are going to have difficulty finding that these applications are so awesome that they justify pushing the PI over the $1M mark? How many of these will be situations in which the PI looks to be losing one of his triggering awards relatively soon, say within a year of funding the scrutinized application…think Councils will not find this a reasonable excuse?

I predict that the number of applications that are rejected after this special scrutiny is going to be very, very small. One, maybe two per Fiscal Year per Institute or Center. At best. This will do nothing to feed all the hungry mouths.

So why is the NIH engaging in this high profile effort?

Quite simply, to throw a few buckets of distracting chum in the water to calm down the people who are lighting the torches and sharpening the pitchforks to go after the bogey man of the excessively funded investigator. And to head off any Congressional snooping/complaining about this alleged ogre of the Extramural system.

As with the Sea World Shamu show, turns out the chum is just ice cubes.

This will have no perceptible effect on success rates for those of us in the 93% or 98.5%.