NIH moves to decrease administrative burden. Riiiiight.

A recent notice (NOT-OD-26-040) informs us that the NIH will no longer require advanced permission from Institutes or Centers for conference grants. For reference to this type of award, if you are not familiar with them, check RePORTER for R13 or U13 mechanisms. Although the NOT reaffirms to us that “NIH’s support of conferences is contingent on the interest and priorities of the individual Institute,Center, or Office (ICO)“, it also claims this is about reducing administrative burden.

As part of ongoing efforts to reduce administrative burden on the applicant community, NIH will remove the prior approval requirement for submission of conference grant applications under the R13 and U13 activity.

This follows a prior NOT (NOT-OD-26-019) that removed the requirement for prior approval of any grants with requests for $500k or more in direct costs. (For some reason the original policy still appears on a NIH online help page.) The new policy says that Letters of Intent will no longer be part of the application process for any purpose, despite re-stating that this was to assist Program with their burden.

NIH has occasionally requested LOIs within Section IV of the Notice of Funding Opportunity (NOFO) to help Institute, Center, and Office (ICO) staff estimate the potential peer review workload and recruit reviewers.

It then states that

Given NIH’s centralization of peer review processes to improve efficiency and strengthen integrity through the Center for Scientific Review (CSR), the LOI is no longer serving the same purpose to estimate ICO workload. To further increase efficiency and minimize applicant burden, NIH is removing the LOI from the application process.

So this part at least is about minimizing applicant burden. Sounds good, right? Also, the NOT informs us that:

Effective immediately, NIH will no longer require applicants requesting $500,000 or more in direct costs (excluding consortium F&A costs) in any one budget period to contact the funding Institute or Center (IC) before application submission. In line with this change, applicants are no longer required to include a cover letter identifying the Program Official contact which notes that the IC has agreed to accept assignment of the application.

In this case it doesn’t directly reference burden on the applicants.

One thing that is consistent about these moves is that it removes Program staff from a gate-keeping position. Previously, Program Officers could reject requests to approve a conference support application, a big budget R01 or applications for targeted funding opportunities that required a LOI approval.

No doubt some of you, Dear Reader, cheer this change. No longer are you subject to the whims of some Program Officer that hates you or has some buddies they need to take care of first, right? Why should they get to head off your chance to have peer review decide if this is an appropriate expenditure of NIH funds? Why should that long running Gordon Conference that bores you get to keep getting funded while your idea for a new and fresh scientific conference cannot gain support before even being allowed to try?

Why should your R01 proposal be subject to an entirely arbitrary $499,999 direct cost limit, especially when this has not been changed in decades and is something on the order of half of the spending power it was when your more-senior colleagues first got their big R01s funded?

I get it. I get your frustrations. I have had them myself, particularly where it comes to the less formal and workaday interactions where Program staff express themselves less than enthusiastic about my latest ideas, even if they do not have a formal way to gatekeep. As you know, I have occasionally observed that sometimes you have to just submit the grant even if the seemingly relevant Program officer isn’t supportive. I have noted how a good score from a study section has a way of countering programmatic reluctance. Gatekeeping can be a bad thing.

Gatekeeping can, however, also be a good thing.

With this new policy, the devil will most assuredly be in the details.

We are in a time in which it is very clear that NIH funding of science projects will be used, in part, to prosecute a political agenda (e.g., trying to tag Pete Buttegieg with lasting consequences of the Norfolk Southern train derailment). It is clear NIH funding will be used to prosecute the alleged health agendas of political people. There will be an explicit effort to award funds to some projects designed more to prove some theory associated with the regime (e.g., herd immunity, environmental causes of autism, weird ideas on healthy eating) than to illuminate facts. The regime is signalling quite overtly that they plan to award NIH funding preferentially to Red states and institutions that kowtow to their attacks on various things, regardless of peer review merit.

A smart apparatchik might understand that until they replace every serious person from Program, there is a risk that grants to support, say, a conference of anti-vaxxers, or mega R01s designed to prove the Tylenol theory of autism, or the health benefits of the inverted food pyramid would simply be disallowed. They might fear that proposals from traditionally lesser-funded States or institutions might not be automatically accepted if they are deemed lesser in merit or priority.

So one simple solution is to remove the gatekeeper function from the Program staff.

Keep your ears peeled. I bet we are also going to see a sea change in the informal discussions with Program. I bet POs are going to be less assertive about discouraging (certain kinds of) proposals, particularly from specific regions of the country.