Since 2009, the NIH has not allowed the resubmission (otherwise known as an “A1”) of a failed application without a significant change to the scope and content of the science. Well, times they are a changin’. Last week, NIH announced a policy change that allows for submissions of similar ideas that were unsuccessful in the past. While the new policy still allows a single resubmission per application, ideas that were unsuccessful as a resubmission (A1) may now be presented in a new grant application (A0) without having to materially redesign the content and scope of the project. This policy applies to all NIH announcements that allow resubmissions, including: FOAs for research grants, the NIH Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs, Career Development Awards, Individual Fellowships, Institutional Training Grants, Resource Grants, Program Projects, and Center Grants.
NIH’s policy for accepting overlapping applications stays the same (see NOT-OD-09-100). The NIH will not accept duplicate or “highly overlapping” applications under review at the same time. This means that the NIH will not review:
- a new (A0) application that is submitted before issuance of the summary statement for a new (A0) or resubmission (A1) application that is considered “overlapping”;
- a resubmission (A1) application that is submitted before issuance of the summary statement for the previous new (A0) application;
- an application that has “substantial overlap” with another application that is pending appeal of initial peer review (NOT-OD-11-101).
Additionally, NIH will not accept a resubmission (A1) application that is submitted later than 37 months after the receipt date of the application that it follows (see NOT-OD-12-128 and NOT-OD-10-140). There is, however, no time limit between an unsuccessful resubmission (A1) application and a subsequent, new (A0) application; or between an unsuccessful new (A0) application and a subsequent new (A0) application (see NOT-OD-14-082).
What this means: The ability to submit a previously-rejected idea as new frees it from previous negative associations; that is, you don’t have to respond to previous reviews or carry the burden of prior analysis. This gives ideas the possibility of maturing before resubmission without the penalty of being presented before their time. In fact, reviewers will be briefed on review as new ideas, even if they have seen it in previous cycles. Another advantage is that applicants will be able to consider previous reviewers’ comments in strengthening their applications for each submission, even without having to answer for them. In addition to future submissions, this also applies to previous “virtual A2s”, meaning that an application that was not accepted earlier for being too similar to a formerly-reviewed resubmission (A1) application can now be submitted now as a new (A0) application.
For further explanation as to implementation of the new policy, check out NOT-OD-14-074, its clarifications, and the Resubmission Frequently Asked Questions pages. Dr. Sally Rockey also has an excellent explanation as to the thought behind the policy change on her blog, Rock Talk, from April 17, 2014.