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Re: NIH gets tough with corrections Bob Beattie 05 Dec 2007 16:09 EST

I suggest that Grants Office Staff -- SO's -- should, without
question, reject applications at the request of the PI, up to the
second day after the deadline (the two day correction window) to
allow for the correction of whatever errors the PI finds -- typos,
wrong files attached, including fixing warnings, and such, but not
substantive changes (but difficult to stop).  At the same time that
the PI found these kinds of errors in an assembled application, the
system generated errors should be found as well and could be fixed
too.  But if they are unnoticed or do not yet crop up, then there is
another two day window after that resubmission gets reassembled.

If we do not allow for the fixing of anything in that first two day
window, extra clever PI's will just build in a Warning causing item
and thus have the reason to check and  re-do the file if necessary.
Ostensibly to fix the Warning.

As long as NIH is allowing two days to fix errors after the
submission, and will even accept changes due to warnings, after the
application is assembled, they cannot, in good conscience, prevent a
PI from fixing typos or other non-substantive problems that shows up
in the assembled document, being seen for the first time by the PI in
final form.  If NIH or Grants.gov cannot provide a way to view, prior
to submission,  the application as the reviewers will see it, then
the PI must be allowed to fix such things.

It would be much better if there were a pre-submission way to view
the final application.  I wonder why after two years no one has been
able to create a program to do this.  There are vendors who have S2S
programs that find errors, but does any show a final application as
it would be after assembly by NIH.  Why cannot there be a "test
server" to which an application can be sent to get a look at what the
final assembly would do? Until then, we must allow PI's to fix the
appearance of the application.

Even after NIH becomes like other agencies and allows no post
submission fatal error fixing, there must still be the two day
viewing window, even one day, so PI's can see what the reviewers see
and have at least one chance to make corrections of a non-substantive
nature.

Best yet, would be for all submissions to be not only on time, but
with enough time prior to the deadline to allow the PI to view and
fix the assembled file.

Bob
xxxxxx@umich.edu

On Dec 5, 2007, at 3:17 PM, Foster, Kathleen C wrote:

 From reading the NIH Guide announcement, it seems to me that the
only acceptable reason for submitting a changed/corrected application
after the deadline is to correct an error/warning identified by the
Commons validation process. We now have two business days to do this
instead of five. The announcement states explicitly that:

(1) All application corrections must be in response to a system-
identified error/warning (application submissions with additional
changes may be refused), and

(2) If final submission is sent after the receipt date, a cover
letter attachment must be included identifying the system-identified
errors/warnings that have been corrected.

My interpretation is that we could reject a successful submission and
submit a changed/corrected application before the deadline to change
something the PI didn’t like about the application (although NIH does
not encourage this); however, this option no longer exists post-
deadline (if, in fact, the option officially existed at all before).

The fact the application is visible in the Commons for two business
days before it moves on to the Division of Receipt and Referral
doesn’t help you much once the deadline has passed. You could reject
and resubmit to correct system-identified “warnings,” but you aren’t
allowed to correct anything else, at that point. I understand the
point that, perhaps, no one would notice if you made other changes;
however, NIH has stated in writing that such applications could be
refused. It seems very risky to me to tell PIs anything other than
what NIH has stated. Perhaps my approach is overly conservative,
though. Could someone from NIH clarify this point for the ListServ?

Kathleen Foster

Director, Research Systems and Funding Information

Office of Sponsored Programs

Boston University

p: 617.353.4365

f: 617.353.6660

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