Re: NIH gets tough with corrections Bloomberg, Robert 05 Dec 2007 14:34 EST

The "PI detected error" is often only found AFTER the errors/warnings have been corrected.  I believe that the reason for the second two day period is to give the PI time to correct those errors.

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@hrinet.org]On Behalf
Of Bob Beattie
Sent: Wednesday, December 05, 2007 2:17 PM
To: xxxxxx@hrinet.org
Subject: Re: [RESADM-L] NIH gets tough with corrections

Are there not three types of corrections and time given for each,
after the deadline?

First, there is the 2 day "error correction window."  This requires
that the application be originally submitted by the NIH 5pm
deadline.  These are NIH errors that must be fixed before the
application can be assembled. Too many pages, problem with IRB info,
etc.   These errors can then be corrected, the application marked
"corrected" in box 1, something put in box 4, a cover letter
explaining the reason for lateness attached, and whole thing
resubmitted.  These errors I call "NIH detected errors."

The second type of error that can be corrected in the "error
correction window" is the PI detected error. Again submitted on time.
Are these any less important than the ones found by NIH?  I am
suggesting that the typos and bad attachments that Charlie mentions
can be dealt with in this "error correction window" time, just as the
NIH detected errors are.  The process is a little different.  An SO
must reject the application in the Commons, but then the process is
the same as I note above. It is much easier to see these errors after
the whole application is assembled.  If this cannot be done prior to
submission, then the checking is done afterward.  Perhaps people have
not thought of these types of corrections in the same context as the
NIH detected errors, but they seem the same to me.  These are errors
in the application due to mistakes made by the PI and research/admin
team.  Sheri Cummins says fixing warnings fits into this category too.

Note as Sherie Donahue writes, this can be a gamble as NIH may not
accept a rejected application, but I would argue that this type of
correction is no different from allowing the PI to correct the NIH
error.  Within two days, there should be no limit to accepting a late
application that has an original valid date stamp.  We would hope
that the PI and supporting staff will get the thing right in the
first place.  Moreover, we do not want people building in NIH errors
to just get two extra days to work on the text.  I do not believe,
however, that there is any way to detect changes in attachments or
budgets when a corrected application is resubmitted.

The third type of error correction is the system generated error that
is found after the application is assembled.  This is much like the
second type of error, in that the application needs to be rejected
and the problem fixed.  The difference is that this error occurs
after the application is submitted and is thus a "system generated
error."  Tables are up side down, or pages are out of order.  The
grants office have a dilemma with this situation.  Prior to a
deadline, do they allow an application to be rejected for any
reason?  I suspect so.  Reject and resubmit, no cover letter needed.
After a deadline, can an application be rejected for any reason and
resubmitted or does the Grants Office staff need to see the actual
system error, and in this case acting on behalf of the sponsor make a
decision as to whether it should be rejected.  I suggest that any
application can be rejected during the "two day correction window"
for any reason, but after that, then there must be strict
interpretation of the "system generated error" situation.

So, in summary, if NIH allows two days to fix errors they find, then
the PIs should be allowed the same time to fix any errors they find.
After that two day correction window period, then the stricter
"system generated error" rules apply.  In all the cases a cover
letter is needed for submissions after the deadline.

What happens if an application has errors when it is submitted at the
end of the two day window?  Is there another 2 days added on?  I
would like NIH to state that there is then no additional 2 day
window, except for extraordinary problems that the help desk cannot
solve. Still 2 more days to check on system generated problems.
After 4 days, at the most, close up shop for that deadline.  Or get
ready for those PI's who have some sort of extension. Perhaps soon,
the "error correction window" will be eliminated, and only the
"system generated error" corrections will be allowed.

Bob
xxxxxx@umich.edu

On Dec 5, 2007, at 1:11 PM, Charlie Hathaway wrote:

> Hypothetically - Does this mean if I submit a grant at 4:59 p.m. on
> deadline day (and it clears grants.gov edits so I have the grants
> ID #)
> but then errors out when it gets to NIH that I have two days to
> resubmit
> it?  And THEN two days to view it (and resubmit it again if necessary)
> to correct other "fatal" errors?

Yes.  But "fatal" errors must be caused by NIH...not typos that you
made.

And cover letters, now required with reference to specific errors/
warnings, and I presume specific reference to the "NIH system error",
are required for ANY submission after the deadline.

My original question was whether corrections to fix typos, and
assorted other "mistakes" are permitted BEFORE the deadline.
Everyone seems to be thinking that this is OK...but the announcement
seems to contradict that.  I am thinking that NIH does not want to
say that 100 submissions to correct anything is ok because they don't
want Commons used in that way.  I just want to know if someone will
get dinged for it.

CH

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