News From C3

June 15, 2013

Two Birds, One Stone:Is it Ok to Simultaneously Submit the Same Proposal to Multiple Agencies?

The short answer to that question is Yes, but probably not as often as you would like it to be. The longer answer is, like most things that fall under governmental regulations, not straightforward. It’s important to get the details right with any funder you apply to, though, lest you end up barred from applying to NSF, or other federal funders, due to failing to adhere to their requirements. In the NSF’s 2012 Annual Report, you can read about all the money they took back from funded investigators for various violations, including that of asking for money from different agencies for research that was too similar. http://www.nsf.gov/pubs/2012/oig12002/oig12002.pdf; scroll down to the scarily titled “Civil and Criminal Investigations”. And, don’t forget that when money is tight, oversight becomes tighter also. Younger or less-established investigators often want to submit the same research to multiple funders because their chances of getting funded on any single submission are lower. 

Lots of time waiting to hear back from funders when you have no funding stream is, naturally, unappealing. And if you are a new investigator you might have only one really good idea so you need to recycle it until it gets funded. But there are times when everyone—young, old, well-funded, or not so much—would love to submit something to more than one funder. So, when is it ok and,importantly, when is it not ok to apply for funds to do the same work?

How About to the NIH?

First, it’s important to realize that often it is ok to multiply submit, but if you get more than one grant to do the same thing you have to turn one down. You also need to tell everyone up front that you have submitted this research to another funder. The NIH says you can submit the same application to other funders if they are not a “Public Health Service Agency”. For example, you can submit to the Department of Defense, DARPA, or to a foundation for the same project as your NIH submission. However, you must tell them and you must turn down one of theawards if both are funded. Go here to read more, since the devil is in the details. http://www.niaid.nih.gov/researchfunding/qa/Pages/applyboth.aspx#same. This page also has information: http://grants.nih.gov/grants/guide/notice-files/NOT-OD-09-100.html

Or The NSF?

NSF’s rules on this topic are a bit more complicated. They say generally they are ok with proposals going to multiple agencies, with the exception of proposals to the Biological Sciences Directorate. Those cannot go to any other agencies. Their BSD exception has two exceptions, though: if the “program managers at relevant federal agencies have previously agreed to joint review” or if the PI has never been a PI or a co-PI on any award other than his/her dissertation, post-doc fellowship, or research planning grant. Got all that? You can read more here http://www.nsf.gov/pubs/gpg/faqs.pdf.

 

Other Things About Multiple Submissions You May Not Have Thought of

While researching answers for this newsletter, we stumbled on this blog http://science-professor.blogspot.com/2009/09/scientific-overlap.html that had an interesting post related to this topic. The questions and answers by scientists other than the author herself were particularly enlightening, so read them too. For example, is it considered the same proposal if you simply change the protein you are working on but you are doing the same thing you proposed in other research? The consensus was that this is ok. Who knew? These and other questions are likely open to interpretation, though, so when in doubt ask your program officer. You don’t want to end up like this guy: http://www.nsf.gov/oig/search/A08070038.pdf 

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