Coalition Responds to NIH Request for Information on Possible RPG Caps

The Coalition for Pediatric Medical Research submitted a respond to the National Institute of Health (NIH) RFI on possible approaches to cap the number of simultaneous research project grants (RPGs). While submitted via a webform, below is a summary of the Coalition’s comments, including thoughts on potential negative consequences of the proposal as well as alternative ideas for the agency to consider. The Coalition looks forward to continued engagement with NIH on this important issue.

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The Coalition recognizes NIH’s stated interest in funding a larger number of investigators, including those who are early-career and from institutions and in regions that have historically received more limited amounts of NIH funding. The Coalition has long shared the goals of supporting early-career researchers and helping diversify the research workforce and would welcome working with NIH to address these priorities.

But the proposal does not recognize how research is conducted and how early-career researchers are supported today, diminishes and may discourage the role of collaborative research even though it is a tenet NIH’s Gold Standard Science, and could result in funds going to less-meritorious or less-feasible research proposals. Instead of finalizing this proposal, we encourage NIH to work with the stakeholder community on policies and approaches to better support early-career researchers regardless of institution or geography.

Collaboration is essential in science. This is particularly true for child health research, given that pediatric research is a smaller field, with fewer research centers, and mostly limited patient populations in any one locality. It necessitates collaboration. Applying any grant cap policy to multi-Principal Investigator (MPI) awards will disincentivize such collaboration. New cures and treatments come from research programs that are built over time and require a steady and predictable stream of funding, including to recruit and retain well-trained personnel – such as early-career researchers and junior faculty. This policy will introduce significant uncertainty and destabilize the process.

We are very concerned that the proposal is vulnerable to potential abuse and gaming of the system based on the strategies for transitioning awards and that the proposal will ultimately destabilize how early-career investigators develop and progress toward becoming independently supported researchers. We recommend that to address the goal of funding more investigators, including those early in their careers, NIH consider the following approaches:

• If NIH moves forward with this proposal, ensure that the grant gap is not less than 4 awards and that MPI awards are excluded from the calculation. We would also recommend a more precise design of any cap by focusing on total funding and not grant numbers to differentiate between grants that are sizable and those that are modest. Also consider possible phased approach to caps, a transition period to address existing awards, and creating a well-defined process for pursuing an exception or waiver. We support the current exclusion of institutional training (T) and career development (K) awards and encourage excluding the R03 (small research grants) code and considering exclusion of other smaller RPG award codes.
• Increase support for training and career development awards that have been proven to be highly effective in developing early-career researchers into independently supported researchers. By supporting proven models with demonstrated records of success, NIH can ensure these resources from taxpayers are invested most effectively. NIH should establish – and appropriately fund – additional early-career investigator-focused programs, such as opportunities that are limited to applicants at early-career stages or that provide support for early-career researchers to acquire data sets and tools so that their applications for R01 or other grants can be more competitive for funding.
• Consider establishing an NIH-wide mechanism to prioritize early-career researchers. Rather than penalizing senior researchers by requiring that they relinquish awards, NIH can take measures to prioritize applications from first-time RPG applicants. This would help these applicants reach or exceed a payline cutoff and could be done via a “sliding payline,” “extended payline,” or similar approaches to benefit early-career investigators. This approach could go in both directions by narrowing the payline window for more established investigators with multiple RPGs.
• Develop an initiative targeted to support early-career investigators who have received an initial R01 or similar RPG and who need support to sustain and grow their research programs. This period is often identified as the most critical and challenging for a researcher and is often the time when many opt to discontinue NIH-supported research because of the challenges associated with transitioning to an independently supported researcher. NIH could offer greater paylines for investigators in this space to mitigate these challenges and maximize the likelihood of them building a research career.

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