Hi-

While it seems that most people responding seem
to like NIH's idea of abolishing the
post-deadline correction window, there have been
some good points presented arguing why the change
is ill-conceived, or at least fraught with danger.

I think NIH is proposing this primarily to 1)
save time and money generally but also 2) create
a "fair and consistent submission deadline"
WITHOUT having to spend tons of money enforcing
the rules about what gets changed
post-deadline.  The latter would require way too
many human hours for NIH to do the police
work.  Their argument that this will reduce time
to process applications etc etc isn't so convincing.

Some have suggested alternatives (add-ons) to the
complete abolishment of the correction
window.  Some of these sounded good but I think
many were based on the particular view of
internal submission procedures from one
institution's perspective.  We differ a lot in
how we navigate the NIH submission
process.  Consider the variations in internal
deadlines, how much of an application we review
in order to approve it, if the PIs can submit
their own proposals after internal approval, time
zones (does Commons handle questions at 7:45 EST
for people in Oregon as well as handle my New
York questions at 4:45?), the knowledge and skill
of the PIs and administrators assembling and
checking proposals, and related, as Bob
mentioned, if applicants have really good
pre-proposal error checking.  The latter is
important.  S2S gadgets are great but don't cover
100% of problems.  As Steve has just mentioned,
Adobe forms may need much much better error pick-up.

I think this argues for NIH not trying to second
guess our internal processes and just applying a
simple, but very "tough love" approach.

As for the conceptualization of "deadlines"...the
term originates from prisons where inmates were
shot (dead) if they crossed a line.  For the
warden, it was clear and simple (and
economical?).  For the prisoners, it also had to
be understood clearly but the issues were more
complex:  how close does one get to that
line?    Sorry for this analogy but I think the
challenge for us is to create internal processes
that keep people from crossing the line or at
least becoming very aware of the consequences if they slip.

Charlie

At 12:25 PM 3/17/2010, you wrote:
>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
>
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>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>
>
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