Re: NIH considering eliminating correction window, seeking comments Paffrath, Dennis 17 Mar 2010 11:25 EST

I really hope that this does become a reality.  We are now looking at if there is a strict deadline of 5pm, we would internally create a deadline of 1 pm so that if an error is caught, we would be able to correct it.  If they do not follow our internal deadline, we cannot guarantee that their proposal will be accepted.  I think each institution will need to put formal internal deadlines so that they can address this issue.  Of course we already have a recommended internal deadline for processing of proposals, but most of our faculty do not abide by this recommendation.  Our recommended deadline is 3 working days within ORD.

Dennis

On Mar 17, 2010, at 10:32 AM, Jean M. Murphy wrote:

How about two hard deadlines?  The first deadline at 2 or 3pm for submission of the application.  The second deadline at 5pm for correction of all errors.  The only applications in process between the first and second deadline are those that came up with errors.  If the application failed to go through at the first deadline for silly little errors that take minutes to fix, you have time to correct it and send it on.  If the application failed at the first deadline for a more fatal error that you don't have time to correct then it fails to move on as it should.
Jean

Research Administration Discussion List <xxxxxx@hrinet.org<mailto:xxxxxx@hrinet.org>> on Tuesday, March 16, 2010 at 4:39 PM -0400 wrote:
I wonder if instead of eliminating the error correction window, just reduce it to say two or four hours.  That way most of the time issues could be met, yet still allow time to correct the little errors that could keep the proposals from being reviewed.  The only deadline I think submitters are going to understand is “if not submitted by this time, deal is over”.  Trying to build internal deadlines apart from the Sponsor deadline appears to be ineffective for most institutions (or we would not even be talking about this) so some type of error correction window I think will always be necessary.

From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Bloomberg, Robert
Sent: Tuesday, March 16, 2010 12:25 PM
To: xxxxxx@hrinet.org<mailto:xxxxxx@hrinet.org>
Subject: Re: [RESADM-L] NIH considering eliminating correction window, seeking comments

New paradigm?  The computers win!  Kafka rules!  5PM doesn’t mean 5PM any more, it means 3PM, or some other arbitrary internal deadline you impose.

Robert P. Bloomberg
Director, Office of Grants & Contracts
Tufts Medical Center
800 Washington Street (Tupper 10)
Boston, MA  02111
Tel.   617.636.1142
Fax.  617.636.8568

________________________________

From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Charlie Hathaway
Sent: Tuesday, March 16, 2010 3:15 PM
To: xxxxxx@hrinet.org<mailto:xxxxxx@hrinet.org>
Subject: Re: [RESADM-L] NIH considering eliminating correction window, seeking comments

New paradigm!  Deadline no longer means when you submit something...it means when an error-free application is accepted.

I imagine that the vast majority of problem submissions ARE the result of myriad little things like Commons user name, etc.  AND...they take minutes to fix.  So...we all set our own internal deadlines!  I bet even 3 PM on a deadline day would be sufficient to cover the stuff.

Did you ever miss an air flight because of traffic or the dog ran away when you were about to leave?   Do you now leave earlier?  Do you still have the dog?

CH

At 02:42 PM 3/16/2010, you wrote:

I remember a time, long long ago, when a deadline of 5PM meant 5PM not 5:05, or any other time.  Of course, if you got your proposal in by 5PM (even as late as 4:59), even if it had a typo, or a wrong DUNS number, or had a miscalculation of a number, or any of a myriad of other insignificant, easily corrected by a human, errors, IT WAS ACCEPTED!!  Amazing.  But I was there I saw it happen.  In fact, I was a Contracting officer for the Air Force, and accepted proposals at 4:59.  With errors.

Now, a deadline of 5PM means nothing, because there is no assurance that it will be accepted, or even reviewed for acceptance, by 5PM.  Without an error correction window, under the current system, there will be otherwise acceptable proposals, submitted on time, but lost because someone forgot to include an eCommons user name.

As long as this is the case, we need an error correction window.

Robert P. Bloomberg
Director, Office of Grants & Contracts
Tufts Medical Center
800 Washington Street (Tupper 10)
Boston, MA  02111
Tel.   617.636.1142
Fax.  617.636.8568

From: Research Administration List [ mailto:xxxxxx@hrinet.org<mailto:xxxxxx@hrinet.org>] On Behalf Of Charlie Hathaway
Sent: Tuesday, March 16, 2010 2:30 PM
To: xxxxxx@hrinet.org<mailto:xxxxxx@hrinet.org>
Subject: Re: [RESADM-L] NIH considering eliminating correction window, seeking comments

I think we should all, as a group, go on record in favor of this.  The benefits will include the end of our "crying wolf" at PIs who KNOW they can be late and push the envelope...and certainly CLEAR rationale for demanding proposals be submitted well before the deadline.  The downside might be vigilante retaliation against our offices.

Thoughts?

Charlie

At 01:31 PM 3/16/2010, you wrote:

Just catching up on Fed Register…and came across this.
The NIH, AHRQ and CDC are seeking comments from the public on the impact of
eliminating the correction window from the electronic grant application
submission process on our applicant organizations in the next year.
 Text of notice is below.
~ Terri

[Federal Register: March 12, 2010 (Volume 75, Number 48)]
[Notices]
[Page 11889-11890]
From the Federal Register Online via GPO Access [wais.access.gpo.gov<http://wais.access.gpo.gov>]
[DOCID:fr12mr10-68]

=======================================================================
-----------------------------------------------------------------------

DEPARTMENT OF HEALTH AND HUMAN SERVICES

Request for Comments on Proposed NIH, AHRQ and CDC Process Change
for Electronic Submission of Grant Applications

AGENCY: Department of Health and Human Services.

ACTION: Process change.

-----------------------------------------------------------------------

SUMMARY: The National Institutes of Health (NIH), the Agency for
Healthcare Research and Quality (AHRQ), and the Center of Disease
Control (CDC) seek comments from the public on the impact of
eliminating the correction window from the electronic grant application
submission process on our applicant organizations and the timing of
such a change.

DATES: To assure consideration, comments must be received by April 19, 2010.

ADDRESSES: Individuals and organizations interested in submitting
comments may submit them electronically via http://grants.nih.gov/cfdocs/era_process_changes_rfi/add.htm
Although submission via the web is the preferred method of submission as it expedites analysis of
comments, e-mails will also be accepted at xxxxxx@od.nih.gov<mailto:xxxxxx@od.nih.gov>

FOR FURTHER INFORMATION CONTACT: Megan Columbus, NIH Program Manager
for Electronic Receipt of Grant Applications, 6705 Rockledge Dr, Suite
5040, Bethesda, MD 20892, e-mail xxxxxx@od.nih.gov<mailto:xxxxxx@od.nih.gov> concerning programmatic questions.

SUPPLEMENTARY INFORMATION: In December 2005, when NIH began its
transition from paper grant application submission to electronic
submission using a new application form and the Federal portal,
Grants.gov<http://Grants.gov>, the agency built into the process a temporary error
correction window to ensure a smooth and successful transition for
applicants. This window provides applicants a period of time beyond the
grant application due date to correct any error or warning notices of
noncompliance with application instructions that are identified by
NIH's eRA systems. (The standard NIH error correction window is 2 days,
but it has been temporarily extended to 5 days to facilitate the
transition for applicants to newly restructured, shorter applications.)
The NIH is considering the elimination of the error correction window
within the year.
 Eliminating the error correction window will allow NIH to enforce a
fair and consistent submission deadline for all applicants. In addition,
eliminating the error correction window will help NIH reduce the time
needed to process applications and forward them through the peer review process.
 The error correction window was established at a time when an
application could take multiple days to get processed by Grants.gov<http://Grants.gov> and
NIH's eRA systems. The lengthy processing time meant that applicants
who applied on time might not receive feedback on the status of their
submissions in time to address system identified errors/warnings until
after the due date, unless they applied well in advance.
 During the initial transition the error correction window also
provided an opportunity for applicants to become familiar with the use
of the new SF424 (R&R) applications and the new way that long standing
business rules would be enforced by electronic systems upon submission.
 Since 2005, combined system processing times have improved
dramatically, with applications now taking minutes to process through
both systems on average instead of days. This improvement provides
applicants timely feedback on the status of their applications and
allows them to address any system identified errors and warnings
immediately, as the systems can process multiple submissions within a
short period of time. NIH also has policies in place that do not rely
on the error correction window to ensure that applicants are protected
from possible eRA Commons or Grants.gov<http://Grants.gov> system issues that might keep
an application from being received by the submission deadline.
 Additionally, elimination of the error correction window will not
affect an applicant's ability to submit late applications under the
existing NIH Policy on Late Submission of Grant Applications (NOT-OD-
06-086 available at http://frwebgate.access.gpo.gov/cgi-bin/leaving.cgi?from=leavingFR.html&log=linklog&to=http://grants.nih.gov/grants/guide/notice-files/NOT-OD-06-086.html
or for those who have provided substantial review
service to NIH to take advantage of NIH's continuous submission policy
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-08-026.html

 NIH is accepting comments from individuals and organizations on the
impact of this change. We are also interested in feedback on possible
timing of the change. Is there support for making the change in the
next 3-6 months, a year, or is more time needed to make the change
should the agencies decide to move forward?

 Date: March 9, 2010.
Sally J. Rockey,
Acting Deputy Director for Extramural Research, National Institutes of
Health.
[FR Doc. 2010-5474 Filed 3-11-10; 8:45 am]
BILLING CODE 4140-01-P

Jean M. Murphy
Deputy Director for Finance and Administration
Wellesley Centers for Women
Wellesley College, Cheever House, 106 Central Street, Wellesley, MA  02481
E-mail:  xxxxxx@wellesley.edu<mailto:xxxxxx@wellesley.edu>      Phone:  781-283-2517     Fax:  781-283-2504
http://www.wcwonline.org

====================================================================== 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") ======================================================================

Dennis J Paffrath
Executive Director for Research Administration
University of Maryland, Baltimore
620 W. Lexington Street, 4th Floor
Baltimore, MD 21201
410-706-6723
xxxxxx@umaryland.edu<mailto:xxxxxx@umaryland.edu>

======================================================================
 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")
======================================================================