NIH Policy on Resubmission Applications
Updated: September 27, 2011
NIH policy on submitting resubmission applications has evolved since 1996. At that time NIH stopped accepting A3 or higher amendments to an application (see NIH Guide Notices of June 14, 1996 and June 27, 1997) and adopted a policy limiting the number of amendments to two. In 2003, (see NOT-OD-03-041), the NIH reiterated the policy on the number of amended applications permitted and eliminated the two-year restriction on the receipt of those applications. A change in policy was announced in October 2008 (see NOT-OD-09-003 and NOT-OD-09-016). A clarification was announced in April 2010 (NOT-OD-10-080). Beginning with original new applications (i.e., never submitted) and competing renewal applications submitted for the January 25, 2009 due dates and beyond, the NIH now accepts only a single resubmission (A1) to the original application. This revised policy was implemented in order to facilitate funding of high quality applications earlier, with fewer resubmissions.
Original new and competing renewal applications that were assigned to Councils up through August 2009 were permitted two resubmissions (A1 and A2). For these “grandfathered” applications, NIH A2 applications had to be submitted no later than January 7, 2011; A2 resubmission applications are now no longer accepted by NIH.
Any second resubmission (A2) will be administratively withdrawn and not accepted for review. Applicants who fail to receive funding after two submissions (i.e., the original and the single amendment) may submit another application that must be fundamentally changed to qualify as new. A new application is expected to be substantially different in content and scope with more significant differences than are normally encountered in a resubmission application. Re-wording the title and/or Specific Aims or incorporating changes that are in response to comments in the previous Summary Statement does not constitute a substantial change in scope or content. Changes to the Research Plan should produce a significant change in direction and approach for the research project. Thus, a new application would include substantial changes in all sections of the Research Plan. Requests for review by a different review committee or funding consideration by a different NIH Institute are not sufficient reasons to consider an application as new. Submission to a different FOA is also not sufficient to make an application new (there are exceptions for applications following an RFA or changing activity code; see NOT-OD-09-100).
Note that there is a time limit for the submission of the A1 resubmission of a competing application (see NIH Guide Notice NOT-OD-10-140).
The resubmission policy applies to all NIH extramural applications, including applications submitted under 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 Centers. NIH does not anticipate making exceptions for any type of application.
Resubmissions normally are not permitted for applications received in response to a Request for Applications (RFA) unless it is specified in the Funding Opportunity Announcement (FOA), in which case only one resubmission will be permitted. Since an RFA often has special considerations of eligibility, scientific scope, and review criteria, unfunded RFA applications must be resubmitted as new applications to another FOA. This applies only to RFAs. The new application must be submitted on the scheduled due dates for new applications. It must not include an Introduction describing the changes and improvements made; and the text must not be marked to indicate the changes. Similarly, a change of grant activity code (e.g., from an R01 to an R21 or from an R03 to an R01) usually involves a change of eligibility criteria, application characteristics, dollar limits, time limits, or review criteria. These applications also MUST be prepared as new applications. More information on these policies can be found in the NOT-OD-08-019.
Applicants are strongly encouraged to discuss their questions with their NIH Institute/Center contact. FAQs are provided at http://grants.nih.gov/grants/policy/resubmission_q&a.htm.
General questions concerning this policy may be directed to the Division of Receipt and Referral at the Center for Scientific Review, 301-435-0715.