Study Sections: Know Your Place

The NIH loves to have its funded experts confer their vast knowledge on various new perspectives.  After all, what is the point of all that investment without the benefit of leverage?  In order to remove any barriers to expertise, there are deadline privileges that are associated with giving your time to the NIH; but there are separate classifications of study section servitude, and the benefits of each are directly proportional to the amount of time and effort given.  This is extremely important because there is a common misconception that service on study section automatically lends the right to a late proposal review, but this is not so.  Take a look at the difference and know where you qualify before you plan on adjusting your proposal timelines:



The privilege that comes with serving on a single study section is that the NIH considers this service a reason why a late application might be accepted, provided that the service was conferred in the two months preceding or the two months following the deadline; that is, the NIH will take into account service on the section in deciding whether or not to accept the application for review.  Specifically: recent temporary or ad hoc service by a PD/PI that required a commitment of time that could have been used to prepare an application may be an acceptable reason (examples include: serving on an NIH extramural review group, NIH Board of Scientific Counselors or an Advisory Board/Council). For the most recent clarifications on late submission policy and other reasons late submissions might be accepted, take a look at NOT-OD-15-039.

The important thing to note here is that a PI does not have an automatic right to acceptance for review after the deadline by virtue of participating on a study section.  Any reasons for late submission must be in relation to the individual(s) with the PD/PI role on the application; if the NIH does not see a causal link, the application will likely be denied review.



Continuous submission allows members of standing committees (as opposed to temporary or ad hoc) and members with “substantial service” to submit proposals for standing deadlines when they are fully developed.  Eligible for events for credit toward the continuous submission standard are membership in chartered standing study sections, NIH Boards of Scientific Counselors, NIH Advisory Boards or Councils, NIH Program Advisory Committees, and/or peer reviewers who have served as regular or temporary members six times in 18 months.  You can check your eligibility by looking for your name on the list that is updated and posted on the standing Continuous Submission information page.  You may also check your eligibility and meetings counted toward the 6/18 standard by logging into your eRACommons account, selecting the “Admin” tab, followed by the “Accounts” tab, and then searching your name.  A table will appear that will indicate in a column called “CS Eligibility Details” whether you qualify for continuous submission:



Clicking on the “Yes” or “No” in the “CS Eligibility Details” column will give you details as to what was counted toward your eligibility, and what to do if any meetings are missing:




If you’re not sure whether you qualify for continuous submission, we can help you figure it out!  Just remember: the NIH is under no obligation to review your submission if you submit late by reason of participation on a single study section, so don’t extend your timeline and create unnecessary stress!



You’re Late, You’re Late, for a Very Important Submission

It happens.  Sometimes your lab floods, or your building is on fire, or you have to flee the country, or you are inundated with paper by your study section.  And sometimes this happens very close to submission deadlines.  What to do?  Here’s what you must be aware of if you are under the gun:



  • An error free application is successfully submitted to by 5 p.m. local time on the due date.  This means that you must allow enough time to correct any errors that may be returned by 5:00pm on the deadline date; an application that was returned with an error at 4:55p and resubmitted with corrections at 5:02p is late and will not be accepted.
  • When due dates fall on a weekend or Federal holiday, they are extended to the next business day. Free time!
  • Permission to submit late is never granted in advance.
  • On EXTREMELY RARE OCCASIONS, late applications may be accepted when accompanied by a cover letter that details compelling reasons for the delay.  The NIH will decide what is “compelling.”  Specific detail about the timing and cause of the delay should be provided so “an informed, objective decision can be made.”  Only the explanatory letter is needed; no other documentation is expected. This letter is available only to NIH staff who have a “need to know” (such as those with referral or review responsibilities); it is not available to reviewers or other staff.
  • Examples of “compelling” reasons include: death of an immediate family member of the PD/PI, sudden acute severe illness of the PD/PI or immediate family member, or large scale natural disasters. Also, recent temporary or ad hoc service by a PD/PI that required a commitment of time that could have been used to prepare an application may be an acceptable reason (i.e.: serving on an NIH extramural review group, NIH Board of Scientific Counselors or an Advisory Board/Council).

  • Examples of unacceptable reasons for late submissions: failure to complete required registrations in advance of the due date, heavy teaching or administrative responsibilities, relocation of a laboratory, ongoing or non-severe health problems, personal events, review service for participants other than a PD/PI, participation in review activities for other Federal agencies or private organizations, attendance at scientific meetings, or having a very busy schedule. For electronic submissions, correction of errors or addressing warnings after the due date is not considered a valid reason for a late submission. However, if the problem is with or eRA Commons, grounds will be considered on a case-by-case basis.  Be sure to follow the directions for documentation given be the NIH here.

  • Late submissions to the NIH are are governed by NOT-OD-11-035.


Other Agencies

  • Most agencies follow policies similar to NIH.  Check your RFP for specific details, or contact us to help you figure out specific guidelines for your agency.


WSU School of Medicine

  • Any proposal submitted with fewer than the required internal three days lead time is considered late, and a late submission form is required to be filed with the SOM Office of Research.
  • Proposals considered “late” by the School of Medicine that are still before the agency deadline may still be submitted; the late submission form serves as documentation of understanding of responsibility for outcomes.  Assistance with late submissions by the RAS office is entirely dependent on volume of on-time submissions.
  • The policy and late submission form for the School of Medicine can be found here.


Sponsored Program Administration (SPA)

  • Proposals must be submitted to SPA a full three business days before the agency deadline.
  • Proposals submitted less than three full University business days before the agency’s deadline will be handled on a first-come, first-served basis, following the completion of proposals submitted on time.
  • Successful submissions of proposals submitted to SPA AFTER the three day window cannot be guaranteed.
  • SPA’s policy is provided on their website, here.


Give yourself some space to breathe: allow yourself enough time to account for the unaccountable! If you have an emergency and you don’t know what to do, contact RAS – we’ll do our best to help you through!

The Quick and the Deadlines

Grant submission is a team effort, and each member of the team has a stake in the outcome.  When an award comes in, the PI gets resources for important research, but there are also accountants who manage the flow of funds, managers who handle purchasing, specialists who ensure compliance, and the list goes on.  Lots of people put forth a lot of effort to ensure effective award management, and lots of people work at the front end as well to ensure the highest likelihood that the proposal for funds receives every consideration.  This is why there are internal deadlines for submission that predate the deadline for application imposed by the sponsor.  Sponsored Programs Administration (SPA) at WSU is responsible for submitting all external requests for funding on behalf of the University, and therefore need time to review and make sure that outgoing proposals are compliant.  SPA requires that all outgoing proposals be submitted three (3) full business days before the agency deadline for proper review (SPA’s policy can be found here).  The WSU School of Medicine also enforces this policy, and requires that all proposals submitted from any School of Medicine department after this deadline be acknowledged by the department chair and recorded in the School of Medicine Office of Research.  For the School of Medicine Late Submission Form and Policy, please follow this link.

An internal deadline is not meant to be a cruel imposition on already time-constrained researchers.  Rather, applications submitted on or before internal deadlines are given earlier and more thorough administrative reviews.  When a GCO or administrator is not in a time crunch, their reviews will be more valuable rather than just glancing through the application to verify the compulsory elements. When time is available
to give meticulous component review (such as  human subjects statements, budget justifications, conflict of interest, etc) it increases the likelihood of a smooth review of the application by the sponsor’s scientific review
panel. Extra consideration beyond the departmental office only improves the quality of the proposal, and ensures the elimination of errors that can be chalked up to haste.

A cursory survey finds that most major research universities impose a standard five-day internal deadline; as stated above, for now, WSU requires three.  To read more about other university standards and how they promote deadlines, check out NCURA’s article in the December 2010 issue of their magazine (p 18).