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