NOSI for URM Investigators: Choose Wisely

I was recently describing Notice NOT-NS-21-049 Notice of Special Interest (NOSI): NIH Research Project Grant (R01) Applications from Individuals from Diverse Backgrounds, Including Under-Represented Minorities in the context of the prior NIH Director’s comments that ESI scores got worse after the news got around about relaxed paylines.

One thing that I had not originally appreciated was the fact that you are only allowed to put one NOSI in Box 4b.

Which means that you have to choose. If you qualify as an individual from diverse backgrounds you could use this, sure. But that means you cannot use a NOSI that is specific to the topic you are proposing.

This is the usual NIH blunder of stepping on their own junk. How many ways can I count?

Look, the benefit of NOSI (and the predecessor, the Program Announcement) is uncertain. It seemingly only comes into play when some element of Program wishes to fund an award out of the order of review. Wait, you say, can’t they just do that anyway for whatever priority appears in the NOSI? Yes, yes they can….when it comes to the topic of the grant. So why do NOSI exist at all?

Well…one presumes it is because elements of Program do not always agree on what should be funded out of order of review. And one presumes there is some sort of conflict resolution process. During which the argument that one grant is related to the Programmatic Interest formally expressed in the NOSI has some weight or currency. Prioritizing that grant’s selection for funding over the identically-percentiled grant that does not mention a NOSI.

One still might wonder about a topic that fits the NOSI but doesn’t mention the NOSI directly. Well, the threat language at the bottom of some of those NOSI, such as oh I don’t know this one, is pretty clear to me.

• For funding consideration, applicants must include “NOT-DA-21-006” (without quotation marks) in the Agency Routing Identifier field (box 4B) of the SF424 R&R form. Applications without this information in box 4B will not be considered for this initiative.

Applications nonresponsive to terms of this NOSI will not be considered for the NOSI initiative.

So what is a PI to do? Presumably the NOSI has some non-negligible value and everyone is motivated to use those if possible. Maybe it will be the difference between a grey zone pickup and not, right? If your ideas for this particular grant proposal fit with something that your favorite IC has gone to the trouble if mentioning in a NOSI…well….dang it….you want to get noticed for that!

So what can you do if you are a person underrepresented who qualifies for the NOSI NOT-NS-21-049 ? The value of this one is uncertain. The value of any other NOSI for your particular application is likewise uncertain. We know perfectly well the NIH as a whole is running scared of right wing political forces when it comes to picking up grants. We know that this NOSI may be related to the well meaning ICs’ staff having difficulty getting PI demographic information and could simply be a data collection strategy for them.

Cynical you say? Well I had a few exchanges with a fairly high up Program person who suggested to me that perhaps the strategy was to sneak the “extra” NOSI into the Abstract of the proposal. This would somehow get it in front of Program eyes. But….but….there’s the “will not be considered” boilerplate. Right? What does this mean? It is absolutely maddening for PIs who might like to take advantage of this new NOSI which one might think would be used to fix the Ginther Gap. It is generally enraging for anyone who wants to see the Ginther Gap addressed.

It makes me positively incandescent to contemplate the possibility that the mere announcing of this NOSI will lead to study sections giving even worse scores to those applications, without any real assistance coming from Program.

A couple of more thoughts. This doesn’t apply to anything other than an R01 application, which is nuts. Why not apply it to all investigator initiated mechanisms? Trust me, underrepresented folks would like a leg up on R21 and R03 apps as well. These very likely help with later R01 getting, on a NIH wide statistical basis. You know, the basis of the Ginther Gap. So why not include other mechs?

And did you notice that no other ICs have joined? NINDS issued the NOT on May 3 and they were rapidly joined by NIDA (May 6) and NIAAA (May 11). All in good time for the June 5 and July 5 submission rounds. Since then….crickets. No other ICs have joined in. Weird, right?

I was on a Zoom thing awhile back where a highly authoritative Program person claimed that the Office of the Director (read: Francis Collins) had put a hold on any more ICs joining the NINDS NOSI.

Why? Allegedly because there was a plan to make this more general, more NIH wide all at one fell swoop.

Why? Who the heck knows. To cover up the reluctance of some of the ICs that would not be joining the NOSI if left up to their own devices? If so, this is HORRENDOUS, especially give the above mentioned considerations for choosing only one NOSI for Box 4b. Right? If they do extend this across all NIH, how would any PI know that their particular IC has no intention whatsoever of using this NOSI to fund some grants? So maybe they choose to use it, for no help, while bypassing another NOSI that might have been of use to them.