FAQs for general guidance to applicants who may be affected by the SCR policy and procedures (see NOT-NS-18-060).

Q.  What does it mean for me if my application is “subject to the new SCR policy”? If you have an application under funding consideration and you will have $1M DC of NINDS research as described above, you are subject to the new policy.  This means that your pending application will be considered for funding: (1) If it receives a percentile score within the more stringent SCR payline or (2) If it is excluded from the SCR payline based on the exemptions listed above and described in further detail below.  Your application will not be recommended to council for funding: (1) If it receives a percentile score outside the more stringent SCR payline unless the research is considered inherently expensive or (2) if it is determined that you do not have sufficient time to devote to the pending application.

Note that, regardless of score, ALL applications will be reviewed to ensure that the Investigator has adequate time available to commit to the proposed project - no score is a guarantee of funding approval.  Applications subject to the SCR policy will be reviewed by NINDS staff, Council, and the Director.

Q.  Are standard administrative cuts factored in when calculating an investigator’s level of research support?  Yes.  Research support is calculated based on the awarded DC of funded grants (inclusive of administrative cuts) and the requested DC (minus IRG recommended cuts and standard administrative cuts) of the pending application.

Q.  How are subawards/consortium costs considered when determining how much research support a PI has?  Subawards and related activities are not excluded when calculating the research support an investigator has on a grant on which he/she is the PI.  That is, the PI is “charged” with the entire cost of the grant (assuming a single PI award) unless the research has been identified as “inherently expensive”.  Subcontracts allocated from collaborating PI’s grant are NOT factored into the research support of the SCR PI.

Q.  The Notice states that only research support for which the investigator is the PI or Co-PI will be considered.  Are investigators with co-investigator and collaborator status impacted?  The policy applies only to PIs or Multi-PIs (e.g. Co-PIs).  It does not apply to co-investigators or collaborators.  Moreover, funds received from investigators in their role as co-Investigator or collaborator will not be considered when determining whether they will be subject to this policy. 

Q.  How is funding attributed for Multi-PI awards or Multi-Component awards when determining the amount of an Investigator’s Research Support?  Only the portion of a Multi-PI (MPI) or Multi-Component award that is attributable to the PI with a pending application will be used.  For the purposes of identifying PIs that may have a pending application subject to this policy, estimated levels of support will be determined by equally dividing dollars among all the research PIs on a project. For example, if there are two PIs on an MPI award, the award DC dollars will be divided in half.  If you believe this attribution of funds is incorrect and may erroneously cause you to be subject to the policy, you should contact your Program Officer to clarify the situation.  At this time, you may be asked to supply Just In Time information documenting your effort on the award(s) in question.  Support received by a PI to lead a core facility on a multi-component grant or cooperative agreement will not be considered in these calculations. 

Q.  How will applications submitted in response to BRAIN, AD/ADRD, and/or HEAL Initiatives be affected by the new NINDS SCR Policy?  In general, applications submitted in response to an FOA supported by Congressionally directed funds will be exempt from SCR unless issues are identified by NINDS program staff and leadership (e.g. insufficient committed effort).  However, investigators should be advised that awards made through one of the programs listed above will, unless it involves inherently expensive research, be included when determining whether a future application submitted to NINDS will be subject to the SCR policy.

Q.  How will the NINDS SCR Policy be applied to non-percentiled applications?  Non-percentiled applications from PIs with greater than $1M in direct costs (including the new application) are also subject to SCR, unless deemed exceptions for the reasons above.  These applications, like percentiled applications, will require a more meritorious score to be considered for funding.  As a general guide, an application will be expected to have a priority score of 30 or better to be funded.  However, there are additional programmatic factors that enter into the consideration of non-percentiled applications for funding.  Therefore, a score of 30 or better does not guarantee funding and a subset of applications with scores above 30 may be recommended for funding.

Q. How will multi-center clinical research projects exceeding $1M/Yr be handled with respect to the NINDS SCR Policy?  In accordance with NIH policy, PIs must obtain agreement from NINDS to submit any application with yearly direct costs over $500K.  At that time, NINDS staff will communicate to the applicant whether or not the project under consideration will be considered inherently expensive, and therefore recommended to the NINDS Council as an exception to the more stringent SCR payline. In most cases, such projects will be considered as exceptions if the PI dedicates effort to the project that is commensurate with the work proposed.

Q. How will therapy development projects that require greater than $1M/Yr to complete research necessary for an FDA IND or IDE be handled with respect to the SCR policy? In accordance with NIH policy, PIs must obtain agreement from NINDS to submit any application with yearly direct costs over $500K.  At that time, NINDS staff will communicate to the applicant whether the project under consideration will be considered inherently expensive, and therefore recommended to the NINDS Council as an exception to the more stringent SCR payline. In most cases, such projects will be considered as exceptions if the PI dedicates effort to the project that is commensurate with the work proposed.

Q.  Can I transfer a grant to another PI to stay under the $1M cap?  For a grant to be exempt from the SCR policy, the transfer must be completed before the application is reviewed. Note as per NIH policy, PI transfers require prior NIH approval.  In addition, changes from a single PI to a multiple PI grant, or changing the number of the PIs on an MPI award will require a new or revised leadership plan.

Q.  I have a pending application which scored within the NINDS payline but will increase my support level to over $1M.  Can I delay the start of this grant until such time that I have under $1M in research support?  No.  As mentioned above and in the Notice, to provide continuity of support a period of 90 days during which an applicant exceeds the $1M cap will be permitted.  Delaying the start of an award to come in under $1M in support will not be permitted.

Q.  Can I terminate an existing grant to stay under the $1M cap?  Yes. However, in order to avoid a delay of funding, the terms of this arrangement must be agreed to by both NINDS and the Institution’s business office at least two (2) weeks prior to the meeting of the NINDS Advisory Council.  If arrangements are not made prior to the Council meeting, the application in question will be put forward with a recommendation of NOT FUND.   For a termination plan to be considered, the grant(s) proposed for early termination must have at least one year of remaining funds (e.g. the final year of the award has not yet been dispersed).

Q.  I have a pending grant which scored at the 12th percentile that puts me over $1M.  Rather than having this grant not funded, can I revise the budget submitted with my application to get my total research support under $1M?  No.  NINDS will not approve budget reductions beyond the standard administrative cuts taken by the Institute (12.5% modular / 17.5% non-modular, with exceptions for specific programs).  A significant reduction of the budget of an application would likely affect the investigator’s ability to achieve the specific aims outlined in the application – NINDS cannot encourage this reduction without potentially undermining the result of the peer review process.

Q. Can I reduce my effort on existing awards to allow “sufficient effort” on my pending application?  Effort reductions to existing awards must be completed prior to the submission of the application in question and are subject to the approval of your Program Director.

Note: The scenarios posed below are based on the FY19 NINDS 16th percentile payline and an SCR payline at the 8th percentile.

Q.  I am currently the PI on 2 R01s and have a pending R01 that scored at the 12th percentile.  This pending application brings my total NIH research support to $1.25M.  Will my grant application get funded?  No, unless one of the exemptions applies.  Your third R01 would need to have scored at or below the 8th percentile in order to be funded.  We encourage you to apply again when you are approaching the end of one of your other two grants

Q.  I am a PI on a recently submitted MPI application that scored at the 15th percentile.  One of the other PIs on our grant application has 3 R01s totaling more than $1M.  Will our application get funded?  No.  The application will be subject to the SCR policy and will not be recommended for funding unless one of the exemptions applies.

Q.  I am the PI of a modular R01 and an R21 that together total approximately $350K in direct costs.  I am interested in moving my research into a non-human primate model that will significantly increase the budget of my next R01 application.  I anticipate the budget of this application will be in excess of $750K DC.  Will I be subject to a more stringent SCR payline?  It is unlikely.  Note that all applications greater than 500k DC/yr require that you obtain permission from NINDS at least six (6) weeks prior to submission (see NOT-OD-02-004).  At that time, NINDS will evaluate your pre-submission proposal and will likely advise you that your non-human primate research is considered ‘inherently expensive’ and therefore an exception from the more stringent SCR payline. Note that this determination will be based on your ability to commit sufficient effort to the application in question and on your level of research support at the time of your pre-submission proposal.   Any changes to your level of research support (e.g. award of an additional grant) may impact this decision.

Q.  I plan to submit a $1M P01 application with a total of 4 PIs / Project Leaders.  One of the project leaders has several NIH grants totaling $1.8M.  All three of the other PIs on the application have only 1 modular R01 each.  Will our application be subject to a more stringent payline?  Most likely.  Note that all applications greater than 500k DC/yr  require that you obtain permission from NINDS at least six (6) weeks prior to submission (see NOT-OD-02-004).  At this time, NINDS will evaluate your pre-submission proposal and will likely advise you that your application will be subject to the more stringent SCR payline.  Note that this determination will be based on your ability to commit sufficient effort to the application in question and on your level of research support at the time of your pre-submission proposal.  Any changes to your level of research support (e.g. award of an additional grant) may impact this decision.

Q.  I do not currently have NIH support; however, I am planning to submit a clinical trial application with a budget well over $1M DC/year.  Will I be subject to a more stringent SCR payline?   No.  Note that all applications greater than 500k DC/yr  require that you obtain permission from NINDS at least six (6) weeks prior to submission (see NOT-OD-02-004).  At this time, NINDS will evaluate your pre-submission proposal and likely advise you that your research is considered ‘inherently expensive’ and therefore an exception from the more stringent SCR payline. Note that this determination will be based on your ability to commit sufficient effort to the application in question and on your level of research support at the time of your pre-submission proposal.  Any changes to your level of research support (e.g. award of an additional grant) may impact this decision.

Q. I have a single modular R01 that funds my discovery research and am interested in submitting a therapy development application in excess of $1M DC/year to gather the necessary evidence to submit an Investigational New Drug (IND) application to the FDA.   If this new application is funded, will the renewal of my modular R01 be subject to the more stringent SCR payline? No.  Note that all applications greater than 500k DC/yr require that you obtain permission from NINDS at least six (6) weeks prior to submission (see NOT-OD-02-004).  At that time, NINDS will evaluate your pre-submission proposal and will likely advise you that your proposed project is considered ‘inherently expensive’ and therefore an exception from the more stringent SCR payline.  When you attempt to renew your R01, your research portfolio will likely be viewed as ‘inherently expensive’. Provided the level of effort committed to both grants remains unchanged, the renewal application will be considered an exception from the more stringent SCR payline.

Q.  I am a PI on several MPI grants but the R01 that funds my lab is up for renewal, putting my research support over $1M.  Am I subject to the more stringent SCR payline?  In most cases, yes: your R01 would need to score at the 8th percentile or better to be funded.  However, there may be occasional exceptions.  For example, if your participation in the MPI awards involves providing a service rather than being directly involved in the research, an exception to the SCR payline may be considered.  Please consult your program director to discuss this situation.