FAQ Pages - Managing Your Grant
- Can I extend the period of my grant?
- What kinds of changes require pre-approval by NLM staff?
- What documentation is needed to make changes to my grant?
- If I change institutions during the grant, can I take the grant funding with me
- My Notice of Award (NoA) says the grant is subject to Streamlined Noncompeting Award Procedures (SNAP) - what does that mean?
- If I invent something during my grant, who owns the invention?
- What kinds of reports are required during the grant period?
- What kinds of final reports are required after the grant ends?
- What happens to my application if I don't get funded?
- If I don't get funded, can I apply again?
- Can I resubmit an unfunded application that was submitted to a Request for Application (RFA) to another funding opportunity announcement (FOA)?
- Is there a benefit to submitting a resubmission rather than a new application?
- What do I have to do to submit a revised application?
- Do I have to make every change the reviewers suggested?
- What happens to my original application when I submit a revised application?
- How do I submit an appeal of the peer review of my application?
A: The grant's project period can be extended for a period of up to 12-months beyond the original expiration date as referenced in the Notice of Award as long as:
- No term of the award specifically prohibits the extension,
- No additional funds are requested, and
- The project’s originally approved scope will not change.
Effective October 1, 2011, grantees must use the No-Cost Extension feature in the eRA Commons to notify NLM when they exercise their one-time authority to extend the final budget period of their grant. NLM will no longer accept these notifications via other means. See http://grants.nih.gov/grants/guide/notice-files/NOT-OD-11-098.html. In extending the final budget period through this process, the grantee agrees to update all required certifications and assurances, including those pertaining to human subjects and animal welfare, in accordance with applicable regulations and policies. All terms and conditions of the original award continue during the extension period.
Q: What kinds of changes require pre-approval by NLM staff?
A: Changes such as change in work scope, change in key personnel, change of grantee organization, etc. always require prior approval by NLM Grants Management and Program Staff. Prior approval is required to rebudget funds awarded for trainee stipends as well as tuition and fees on NLM training grants or from patient care costs on traditional research grants. In most cases you may rebudget funds from one category to another without prior NLM Staff approval. However, there are some budget categories that do require prior approval to changes. For a complete list and explanation of actions that require NLM Grants Management and Program Staff prior approval, refer to Prior Approval Requirements, Section 8.1.3 for specific information.
Q: What documentation is needed to make changes to my grant?
A: A request for a change of principal investigator is made via a countersigned letter (signed by the principal investigator and the administrative official listed on the face page of the grant application). Most other changes can be negotiated through electronic communication with NLM staff assigned to your grant. If using e-mail, follow the guidelines described at http://grants.nih.gov/grants/policy/nihgps_2010/nihgps_ch8.htm for requesting changes that need prior approval.
Q: If I change institutions during the grant, can I take the grant funding with me?
A: You can change institutions in most instances. A request for a change of institutions must be submitted to the designated Grants Management Staff and must be accompanied by a Relinquishing Statement (PHS 3734) and a Final Invention Statement (HHS 568) as well as an application from the proposed grantee. It is strongly recommended that you consult with your Program Officer if you are considering a change of institutions. For additional information, see http://grants.nih.gov/grants/policy/nihgps_2011/nihgps_ch8.htm#_Toc271264936
Q: My Notice of Award (NoA) says the grant is subject to Streamlined Noncompeting Award Procedures (SNAP) - what does that mean?
A: If your grant is subject to SNAP, there are a number of provisions that modify annual progress reports, NoAs, and financial reports. See http://grants.nih.gov/grants/policy/nihgps_2011/nihgps_ch8.htm#_Streamlined_Non-Competing_Award for details.
Q: If I invent something during my grant, who owns the invention?
A: If research findings result in inventions, grantees have the right to retain title to these inventions, as long as they abide by the provisions of the Bayh-Dole Act of 1980, as implemented in 37 CFR 401, for their utilization, commercialization, and public availability. NIH requires that some form of public access be provided the results and accomplishments of activities that it funds. See http://grants.nih.gov/grants/policy/nihgps_2011/nihgps_ch8.htm#_Toc271264974 for more specific details.
Q: What kinds of reports are required during the grant period?
A: A progress report issued under the SNAP provision is due the 15th of the month preceding the month in which the budget period ends. If an award is not issued under SNAP provisions, the progress report is due the first of the month preceding the month in which the budget period ends. For fellowships, the progress report is due two months before the beginning date of the next budget period. Progress Reports for Multi-Year Funded (MYF) awards are due annually on or before the anniversary of the budget/project period start date of the award (see http://grants.nih.gov/grants/rppr/rppr_instruction_guide.pdf for more details). Progress reports for non-competing grant periods should be submitted via NIH eRA Commons using the RPPR form.
Grantees may access a list of progress reports that are due using the Status page in eRA Commons, and selecting the Tab "List of Applications/Grants”. The far right column on the resulting table entitled Action will include an RPPR link if a progress report is due for a SNAP or Fellowship award. Select the RPPR link.
Q: What kinds of final reports are required after the grant ends?
A: Three reports are due when grant funding ends: a Federal Financial Report (SF 425), a Final Project Progress Report, and a Final Invention Statement and Certification. The forms for these reports are available online. See the listing of reports and forms at http://www.nlm.nih.gov/ep/reports-table.html.
Q: What happens to my application if I don't get funded?
A: If an application does not result in funding, there may be an opportunity to respond to the reviewers’ comments and resubmit the application within the appropriate timeframe. Applicants seeking advice beyond that available online may want to contact the NIH Program Officer listed at the top of the summary statement (see http://grants.nih.gov/grants/policy/amendedapps.htm for more information).
Q: If I don't get funded, can I apply again?
A: For all applications with due dates after April 16, 2014,following an unsuccessful resubmission (A1) application, applicants may submit the same idea as a new (A0) application for the next appropriate new application due date (see NOT-OD-14-074). Talk to your NLM program officer about options for your application.
Q: Can I resubmit an unfunded application that was submitted to a Request for Application (RFA) to another funding opportunity announcement (FOA)?
A: Yes, but you must wait until the summary statement for the previous submission is released and you need to look carefully at the requirements of the FOA and/or activity code. Since an RFA often has special considerations of eligibility, scientific scope, and review criteria, unfunded RFA applications may be resubmitted as new applications to another FOA or activity code as long as the application is modified appropriately to fit the application requirements of the new FOA or activity code. Please note the following conditions:
- When an application that was submitted in response to an RFA is not funded and the investigator wishes to submit an application on this topic as an investigator-initiated application, it is to be submitted as a new application, unless provision for a resubmission is clearly delineated in the RFA. In addition, if a subsequent RFA specifically solicits resubmissions of unfunded applications from a previous RFA, the instructions in the second RFA should be followed. In all other cases, an application submitted in response to an RFA and then resubmitted as an investigator-initiated application must be prepared as a new application.
- When a previously unfunded application that was originally submitted as an investigator-initiated application is to be submitted in response to an RFA, it is to be prepared as a new application.
- When an unfunded application that was reviewed for a particular research grant activity code is to be submitted for a different grant activity code, it is to be prepared as a new application. In such cases it is not possible to continue both application lineages and it is not possible to submit a resubmission application for the first activity code. In addition, due to the NIH policy of not allowing submission of, similar, essentially identical, or identical applications, no resubmission under the resubmission policy stated above may occur until after the peer review process is completed and a summary statement has been provided to the applicant.
For additional information see NOT-OD-14-074.
Q: Is there a benefit to submitting a resubmission rather than a new application?
A: It depends on the nature of the specific weaknesses or problems in your application. Some "flaws" are fairly straightforward and simple to identify and correct; others are less so. When reviewers assess an amended application, they look to see how shortcomings identified in the summary statement are addressed, but will also review the entire application, as a whole, for strengths and weaknesses. Sometimes, fixing one set of problems reveals another set. Thus, your priority score could actually worsen for a revised application. Additionally, a resubmission allows you to provide a one page introduction and to mark changes in the text, to tell reviewers directly how you have addressed their critiques. Alternatively, the introduction allows you to explain why you did not address one or more critique(s).
Q: What do I have to do to submit a revised application?
A: Your amended application must contain all the parts of the original application, plus an Introduction and be submitted within 37 months after the date of receipt of the original application. The Introduction to the revised application should summarize additions, deletions, revisions, and your responses to criticisms in the summary statement. All changes in the body of the research plan should be highlighted typographically, e.g., by bracketing, bolding, or italicizing. If the changes are so extensive as to include most of the text, this exception should be explained in the Introduction. If nothing has changed in the budget, resources section, or biosketches, you may use what was submitted with the original application. You should incorporate an updated description of any relevant work performed since the original submission, and updated letters of support. See http://www.nlm.nih.gov/ep/Deadlines.html for receipt dates for resubmissions.
Q: Do I have to make every change the reviewers suggested?
A: You don't have to make all the changes suggested by the reviewers. In the Introduction to the revised application, you should respond to all reviewer concerns and explain your rationale for making or not making recommended changes.
Q: What happens to my original application when I submit a revised application?
A: The revised application will reside in a record distinct from the original application in the NIH administrative data system. The NIH administrative data system has been upgraded to handle multiple versions of an application.
Q: How do I submit an appeal of the peer review of my application?
A: The National Institutes of Health (NIH) policy concerning appeals of the initial peer review process is set-out in the NIH Guide Notice, NOT-OD-11-064.
An appeal is a written communication from a Program Director/Principal Investigator (PD/PI) and/or applicant institution that meets the following four criteria: 1) is received after issuance of the summary statement and up to 30 calendar days after the second level of peer review, 2) describes a flaw or perceived flaw in the review process for a particular application, 3) is based on one or more of four allowable issues (described below), and 4) displays concurrence from the Authorized Organization Representative (AOR).
An applicant who is concerned about procedural aspects related to the completed initial peer review of his or her application should consider the comments in the summary statement, and then should contact the appropriate NIH Program Official (PO) (see contact information in the upper left-hand corner of the first page of the summary statement). The PO can answer questions about the summary statement and review outcome, and provide advice to the applicant. For example, the PO may recommend modifying the application according to NIH policies for resubmission applications (NOT-OD-10-080) and the issues that were raised in the review and communicated in the summary statement, or may recommend reconsidering the basic intent of the project and submitting a new application that has substantial differences in aims and approach (NOT-OD-10-080). At no time should the PD/PI or an official of the applicant organization attempt to contact individual members of the Scientific Review Group (SRG) to discuss the review of an application, as doing so could jeopardize the confidentiality of the review process.
Following discussion of concerns with the PO, if the PD/PI and/or an official of the applicant organization wishes to appeal the outcome of the initial peer review process, an appeal letter must be submitted, either in hard copy or electronically, to the PO. The appeal letter must display concurrence from the AOR of the applicant organization for the application. Although the content of the appeal letter may originate from the PD/PI, Contact PD/PI for multiple PD/PI applications, or an organizational official(s) (not necessarily the AOR), the AOR must send the letter directly to the PO, or must send his/her concurrence to the PD/PI who will forward the materials and AOR concurrence to the PO. A communication from the PD/PI or official of the applicant organization (other than the AOR) only or with a “cc” to the AOR will not be accepted. The PO will send the PD/PI and/or institutional official, and AOR, an acknowledgement letter within 10 days of receipt of the appeal letter.
The ICs may establish deadlines by which appeal letters must be received in order to be made available at the Council meeting. However, in no circumstance will an appeal letter be accepted before the summary statement has been transmitted to the PD/PI or later than 30 calendar days after the relevant Council meeting.
An appeal letter will be accepted only if the letter 1) describes the flaws in the review process for the application in question, 2) explains the reasons for the appeal, and 3) is based on one or more of the following issues related to the process of the initial peer review:
- Evidence of bias on the part of one or more peer reviewers.
- Conflict of interest, as specified in regulation at 42 CFR 52h.5. “Scientific Peer Review of Research Grant Applications and Research and Development Contract Projects”, on the part of one or more peer reviewers.
- Lack of appropriate expertise within the SRG.
- Factual error(s) made by one or more reviewers that could have altered the outcome of review substantially.
Appeal letters based solely on differences of scientific opinion will not be accepted. A letter that does not meet these criteria and/or does not include the concurrence of the AOR will not be considered an appeal letter, but rather a grievance. The IC will handle grievances according to IC- specific procedures. Appeals involving potential conflict of interests or violation of ethical conduct rules on the part of an NIH staff member or other federal employee will be referred to the appropriate Deputy Ethics Counselor for consideration and resolution before any further review of, or action on, the appeal is taken.
NIH staff will consider the basis for the appeal letter, and evaluate the merit of the appeal. If both review staff and program staff support an appeal, then the original application, without additional materials or modifications, will be re-reviewed by the same or a different SRG. In this case, only the results of the re-review, and not the first review, are made available to Council, and information about the appeal is not made available to Council.
If review staff and program staff do not support the appeal, or do not agree on its merit, the PD/PI and/or an institutional official (not necessarily the AOR) may elect to withdraw the appeal letter. The request to withdraw an appeal letter must be submitted either in hard copy or electronically to the PO, and must display concurrence from the AOR of the applicant organization for the application. Although the content of the request may originate from the PD/PI, Contact PD/PI for multiple PD/PI applications, or an organizational official(s) (not necessarily the AOR), the AOR must send the request directly to the PO, or must send his/her concurrence to the PD/PI who will forward the materials and his/her concurrence to the PO. A communication from the PD/PI or institutional official (other than the AOR) only or with a “cc” to the AOR will not be accepted.
If review staff and program staff do not support the appeal, or do not agree on its merit, and the appeal letter is not withdrawn, the appeal letter will be made available to Council. The IC may not deny the PD/PI or applicant organization the opportunity to have an appeal letter made available to Council.
Only two outcomes are possible following consideration of an appeal letter by Council:
- The Council may concur with the appeal, and recommend that the application be re-reviewed.
- The Council may concur with the SRG's recommendation and deny the appeal. Although factual errors or other issues may be evident, the Council may determine that these factors were unlikely to alter the final outcome of the SRG and deny the appeal. No action by the Council is equivalent to concurrence with the SRG’s recommendation and denial of the appeal.
The recommendation of Council concerning resolution of an appeal is final and will not be considered again by the NIH through this or another process. At no time should the PD/PI or an official of the applicant organization attempt to contact individual members of the Council to discuss their consideration of an application or appeal, as doing so could jeopardize the confidentiality of the review process.
The PO will communicate the Council recommendation concerning an appeal to the PD/PI, AOR, and NIH staff with a need to know. If the appeal letter was received by the IC deadline, the PD/PI and AOR will receive a written explanation of the resolution no later than 30 calendar days after the Council meeting. If the appeal letter was received after the IC deadline, the PO will provide, no more than 30 calendar days after the date when the appeal letter was received, a written explanation of the IC’s plan for making the appeal available to Council.
If the Council recommended that the application be re-reviewed, the original application will be re-reviewed without additional materials or modifications. The application may be re-reviewed by the same or a different SRG, depending on the flaws in the original review process that led to the appeal. In most cases, the re-review will entail re-assignment to a subsequent review round and delay in the final funding decision. The outcome of the re-review is final and cannot be appealed again.