According to the following, you would submit as new.
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-03-019.html
POLICY: This general policy on application resubmission, stated below, applies to all grant applications that might be solicited via an RFA and to instances where there is a change in activity code. There may, however, be exceptions to this policy, which will be clearly identified in the original RFA or in a follow-up RFA.
1. When an application that was submitted in response to an RFA is not funded and the investigator wishes to resubmit an application on this topic as an investigator-initiated application, it is to be submitted as a new application, unless provision for a resubmission is clearly delineated in the RFA. In addition, if a subsequent RFA specifically solicits resubmissions of unfunded applications from a previous RFA, the instructions in the second RFA should be followed. In all other cases, an application submitted in response to an RFA and then resubmitted as an investigator-initiated application must be prepared as a new application.
2. When a previously unfunded application that was originally submitted as an investigator-initiated application is to be submitted in response to an RFA, it is to be prepared as a new application.
3. When an unfunded application that was reviewed for a particular research grant activity code (e.g., R01) is to be submitted for a different grant activity code (e.g., R03), it is to be prepared as a new application.

Matthew D. Katz, MHA
Assistant Vice President,
Sponsored Research and Contract Management
Western University of Health Sciences
309 E. 2nd Street
Pomona, CA  91766
xxxxxx@westernu.edu
(909) 469-5567
(909) 469-5569 FAX

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Roseanne Wallin
Sent: Thursday, March 04, 2010 11:19 AM
To: xxxxxx@hrinet.org
Subject: [RESADM-L] Expired Program Announcement

Hello-

I have  PI who submitted a proposal under an NIH Program Announcement that
has since expired, and not been replaced.  She received generally positive
reivews with her first submission and would like to resubmit her application (it's
an R03) but since the PA has expired can we "resubmit" under a Parent R03, or
would this be considered a "new" application?  As an aside, her Program
Officer originally told her that the PA was going to be renewed, or she would
not have applied under it.

Thanks in advance!

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 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
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