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

August 21, 2012

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%.


No Responses Yet to “Special scrutiny for PIs who hold $1 Million in NIH Grant funds”

  1. odyssey Says:

    Two things: first, the Advisory Council that will be making these decisions is full of BSD’s… Second, the inclusion of R29’s in the grants list above is kind of amusing.


  2. Virgil Says:

    You assume here that the BSDs with multiple grants are getting them funded with modular budgets. Most BSDs I’ve met go non-modular, often approaching double the modular budget. For these folks, a couple of awards and you’re dangerously close to the limit. These are usually the same ones who are at or above the NIH salary cap, with the indirects being funneled via the Dean’s office to support their inflated salaries.

    Is this initiative a good thing? Yes.
    Is it too little too late? Yes.


  3. lay person Says:


    What does BSD stand for?.


  4. Genomic Repairman Says:

    Big Swinging Dick.


  5. Dave Says:

    You lost me with the Shamu ice cube thing?????


  6. DrugMonkey Says:

    Virgil- it’s the same amount of money. Which is what really matters and why raging about the *number of awards* is always misplaced. I was just using this as a point of familiar reference.


  7. DrugMonkey Says:

    As far as I can tell they are feeding Shamu ice cubes, not fish chunks as the reinforcer….no doubt conditioned but still. The idea was the empty gesture/lip service nature of this “scrutiny”. IMO, of course.


  8. DrugMonkey Says:

    Wrt Virgil’s point and the percentage of PI’s affected, sure maybe there are a few more picked up with $1M from 2-3 awards but I’d say not many. $500K in direct is another big hurdle, those single awards above this are really rare. So I’d argue the large single R01 theory only drops it from 4 award to 3 award PIs at best.


  9. arthur Says:

    What I am missing here is consistency and determination to advance in the problem NIH is addressing: how best use an inescapable reduced budget to attain scientific productivity and opportunities for best science in this fiscal situation and the future.

    If the pilot study contemplated the “total costs” criterion to determine if a specific PI and/or PIs research portfolio is sustainable under present scientific and monetary priorities, what is the rationale for changing the criterion (direct costs now) and what are the advantages of this change in relationship to the main goal?. OER, please discuss.

    If it is true that Advisory Councils are full of members in the 1.5% of NIH-funded investigators, a fundamental question is whether these members will be totally free and “science common good-driven” to make the best recommendations to achieve the goal?. I doubt it. What is needed is to replace these members, in the Special Council Review, with independent scientists. NIH has a well-organized database and it should not be difficult to find them.

    Determination to advance in addressing the problem requires extraordinary measures for unfortunate extraordinary times.


  10. EAT THE RICH!!!!!!!!11!!1!111!!!


  11. toto@club-med.so Says:

    What’s a “modular” vs “non-modular” award?


  12. drugmonkey Says:

    A reader reminded me of this interactive tool for checking amount of NIH cashola versus percent of PIs. http://report.nih.gov/budget_and_spending/RPG_Support_by_PI.aspx

    12% receive $1M… BUT, it doesn’t say whether this is direct or total costs. given the way they typically describe $ data, I’m going to have to assume total costs. So we should be looking at $1.5M and above..so we’re back to 6% as the elite subfraction.

    toto- in the NIH system if you ask for less than $250,000 in direct costs per year, you specify the budget only as a number of $25,000 “modules”. If you ask for over this it is the “traditional” budget process in which you need to itemize the costs a little bit more explicitly.


  13. toto@club-med.so Says:

    DM: thx!


  14. DrugMonkey Says:

    Rockey’s post on this indicates some 89 apps are expected to trigger scrutiny this round. Higher that I would have expected but still a tiny fraction of the apps they receive.


  15. lawrence Says:

    The impression is NIH’s reluctance to scrutinize and be accountable for their decisions on funding in these very difficult times.

    Asked if there will be an on-going evaluation of this policy, Rockey said yes. BUT, she added: “NIH does not make factors that go into funding decisions (scores, priority pays, etc) public, however, so we do not expect to report on the number of applications that are not funded as a result of this policy”.

    The whole sentence, as phrased, doesn’t show any logic other than in her examples she is mixing up items that belong to the process of peer review ( i.e., scores) and could require confidentiality with other items that belong entirely to the public (i.e. priority pays). She doesn’t seem to grasp the “why’ for policy and priorities.

    It is all PR and no intention of tackling the problem with resolve so that NIH becomes a leading force in advancing effective ways to overcome the challenges the country is facing.


  16. DrugMonkey Says:

    Yeah, Rockey blew that answer. No reason they can’t post the aggregate numbers.

    Now we’re just going to have the usual rumor mill of leaks from Council members. There will always be some of them that tell their colleagues how many apps received special scrutiny and how many were refused funding. each small-N leak will be amplified and confirmation bias will be strongly at work.

    Far better to just publish the data NIH.


  17. Jeremy Berg Says:

    I agree that it is very important that NIH find a way to provide data about the outcome of this policy.

    With that said, this is not as simple as it seems (although not for the reasons that Sally Rockey notes) based on my experiences with the well-funded investigator policy at NIGMS. First, in many cases, the Councils are not going to provide fund/don’t fund input but rather give program staff input about their level of enthusiasm for the proposal given the extra scrutiny. This advice increases or decreases the chance of the proposal being funded but this will depend on the percentile score, available funds, etc. at the time funding decisions are actually made. Second, at NIGMS, the decisions were not quantized (fund or not) in that, in some cases, a proposal was funded but at a greatly reduced level (e.g. $50K direct per year). This provided some funds for the additional project while recognizing that much of the lab infrastructure was already paid for. Despite these nuances, I think NIH should find a way to convey the impact of the new policy in a quantitative manner.


  18. drugmonkey Says:

    I think you are conflating two things, the mechanism with the outcome. The primary question is only about whether or not the application that triggers scrutiny results in a funded application or not. For those of us who are banging on with a degree of skepticism, the major issue here is whether this is meaningful or not. The initiative implies *very* strongly that there is good reason to think that money is best spent elsewhere once a lab gets too “rich”. The assumption is, therefore, that many of these triggering applications *should not be funded*. For this primary question, the actions of Council are not critical- the outcome of the entire process is the key.

    Now true, as this process percolates along I am indeed interested in what Council is saying but that is only insofar as I’d like to assess the aforementioned primary outcome. Just as I’d like to know the details of which apps POs advocate for and which they do not. And which apps result in a given IC director making decisions to sustain or to violate the Council opinion. etc. But again, this level of detail is curiosity compared with the primary concern. Funding success for those applications in the special scrutiny pool should be the focus.

    This part

    Second, at NIGMS, the decisions were not quantized (fund or not) in that, in some cases, a proposal was funded but at a greatly reduced level (e.g. $50K direct per year).

    sounds like more excuse-making. Funded at a “greatly reduced level” is funded. These would be placed in the funded category as far as I am concerned. $50K per year for 5 yrs is 2.5 R03 awards.

    Now, if the various ICs find themselves embarrassed by the fact they are not actually doing much to service this apparent goal then they can feel free to come up with supplemental measures in addition to the success rates. Dollars scrutinized vs dollars awarded or something. Or, they can do something innovative like decide to issue a supplement to an existing award instead of the new award.


  19. Jeremy Berg Says:

    DM: I understand your points and I think your metric (dollar scrutinized versus dollars awards) is a good one that would address some of the nuances that I raised.

    The other issue is the denominator, that is, which applications are scrutinized. What is the percentile cutoff used to determine relevant applications? If an application with a 2nd %ile is scrutinized and not funded, then the policy probably an effect whereas the same would not be true for an application at the 20th %ile.

    I think a plot similar to the NIGMS funding curves with dollars awarded versus dollars requested for scrutinized applications as a function of percentile score compared to a control plot with non-scrutinized applications could be effective.


  20. oncepriviligednowwhining Says:

    Wonder how those BSDs who are the single PI on RC4 grants will be assessed when some of their Total Costs are >$3.3M over 3 years for these wonderous ARRA windfalls that are ending next year if not sooner due to sequestration?

    Wonder how reflective are the BBoomers running the NIH funding charades fully knowing how unsustainable the entire pipeline is and is crumbling before our eyes?

    The prospects of keeping my fledgeling fiefdom running is discouraging, and clearly ESI, fancy pubs throughut grad school and postdoc and “potential” is now shitte to study section, they only want the experiment DONE before it’s worthy science, and if two tries they don’t like it, then for sure the science is too crappy to propose again.

    Am I a whining noob? Yes, probably, but I’m not just sitting on my ass doing nothing but reading this blog either (maybe). Forget any time doing actual research, I’m just going to impale my ass to my chair, endlessly writing applications on the same data that really should be going out for publication before I close shop.

    Great review system we have here. The “Commitment” to the future generation of scientist mantra is lip service, when 70-80 yr olds are still getting grant$. Meanwhile, the Rocky star team is continuing to pat themselves on the back for a system that “works fine”.

    Where do I sign up for my pitchfork?


  21. EAT THE OLDS!!!!!!!!11!1!111!!!!


  22. DrugMonkey Says:


    Since you are hanging around, a couple of retread questions.

    Do you think that the reduction in PIs seeking funding is highly necessary to solve the NIH woes?

    If so, how is that best accomplished? Who gets chopped?

    Can you estimate the degree to which NIH officialdom sees this current situation as a Problem vs the way we investigators see it? Is anyone worried about the immense time waste involved in keeping just a barebones lab going with funding?


  23. Jeremy Berg Says:

    DM: I certainly do feel that the system is “out of equilibrium” in the sense that there are more investigators seeking (and dependent on) funding than the system can support. This evolved out of the NIH “doubling” followed by a decade of budget increases below inflation. Unless the budget situation changes dramatically (for the better) which is unlikely, the number of PIs is going to go down. This is fundamentally a Darwinian system. The key question is: What are the selective pressures?

    The number of applicants (compared to the available funds) is the biggest issue. I do not think any one group will be (or should be) singled out. NIH does need to pay specific attention to support of early career investigators without enccouraging institutions from taking on more faculty that they cannot afford in the longer run. I also do feel that looking at the funding distribution is important. Reducing the amount of funding to a very well-funded laboratory to allow funding for a lab doing outstanding science that is on the edge seems to me to be the right move in terms of the long-term health of the biomedical research enterprise. Peer review does not have the resolution to sort applications differing by a few percentile points and other factors should be considered. The new NIH policy that is the subject of this post seems to me to be a faint-hearted effort, but it may be a good start to a more impactful policy in the longer run.

    I think leaders and staff within NIH are concerned about the current situation, both in terms of loss of investigators and time spent on grant writing, reviewing, etc., but probably do not view it with the level of alarm that is appropropriate. The ARRA funding put off the inevitable pain for a couple of years, but it is clearly coming.

    I have written my President’s Column for ASBMB Today for next month that describes my view of the evolution of the present situation. Nothing profound, but it ends with a call for some serious discussion of relatively bold actions, none of which will be simple or painless.


  24. Pinko Punko Says:

    Unrelated, but someone of an issue: the ESI “10 year” rule from date of degree. In this climate, people take a long time to get jobs, and then funding is much tighter as well. This means I know someone that will have something like an 8 month window as an ESI after starting his first faculty position because of a long post-doc and time off after graduation due to illness in family. This is just not a good policy.


  25. drugmonkey Says:

    The ESI should have been tagged to first faculty appointment, period.
    A major policy blunder in my view.


  26. Jeremy Berg Says:

    There is an extension process that was intended accomodate time off due to illness and other issues. See http://grants.nih.gov/grants/guide/notice-files/not-od-09-034.html

    I do not know if anyone can report any experience with this policy, good or bad.


  27. […] The responsibilities of an academic are teaching, research and service fundraising (must-read; I’ve been saying this for a while now) How many species are there? New species wants you to See No Weevil Helium Shortages Impact More Than Just Birthday Parties Special scrutiny for PIs who hold $1 Million in NIH Grant funds […]


  28. drugmonkey Says:

    It was an academic generation screw job which is why I say it is a blunder. I’ve blogged about this before in the context of saying I don’t feel sorry for myself and people of my approximate generation *who managed to make it over the transition hurdle*. Those of my approximate generation who managed to get their first grant before things really went in the toilet and are now complaining that they are stuck between ESI policies and the OldGuard really digging in their toes (facilitated by their “long term POs”).

    What I usually fail to talk about are those excellent scientists who, for one reason or another*, didn’t happen to get over the hurdle. Then, when they were all long past the ESI interval (and therefore asking for special exceptions was kind of pointless) along comes the NIH “help” for younger investigators…but it explicitly jumped over them and said “too bad folks, we’re just going to ignore you and furthermore, give hiring committees every reason in the world to screw you as well”.

    So, while I do like the NIH giving the Universities a reason to make faculty hires ever closer to the granting of the PhD…this method was a really brutal** choosing of winners and losers in the generational battle***.

    *all too frequently women, all too frequently childbearing, all too frequently accommodating a slightly older academic spouse

    **curious given the relative timidity of the NIH in making other dramatic changes, picking winners, etc.

    **It will not surprise you in the least that I view this as yet more of the Boomers (those who run things at NIH) screwing the GenXers for whom they have zero affinity to benefit the GenY/Millenials who are their generational offspring.


  29. rs Says:

    I have gotten 6 months extension because of two kids (3 months for each kid). Anything else in my career break (2 full years and many small break in between of moving countries and part time work) was considered my choice, even though it was not.

    I had success in getting NIH reentry grant though, once we got our green card. It was pretty straight forward and was the only reason I could restart my career after the break. You need to find a mentor who has at least 2 years left in their NIH grant and who is willing to prepare an application with you.


  30. rs Says:

    and of course I am out of ESI eligibility condition.


  31. Green Card Says:

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    together. I once again find myself spending a lot of time both readinjg and posting comments.

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