Bonus Friday link: NSF’s Bio Directorate removes proposal submission limit for 2019

For the US folks, NSF’s Bio Directorate had an important announcement yesterday, removing the limit on the number of proposals someone can submit as PI or co-PI in 2019. Here’s part of the announcement:

Having listened to community concern and tracked the current low rate of submission, and following extensive internal consultation, BIO is lifting all PI or co-PI restrictions on proposal submission for FY 2019, effective immediately.

BIO recognizes that it is important to track the effects of the no-deadline policy on proposal submission patterns, to ensure that a high-quality review process is sustained. Therefore, we are seeking approval from the Biological Sciences Advisory Committee to establish a subcommittee to assist in developing the evidence base for any future policy changes that may be needed.

I think this is great news! And I completely agree with Mike Kaspari:

13 thoughts on “Bonus Friday link: NSF’s Bio Directorate removes proposal submission limit for 2019

  1. Honest question (though I’m sure it sounds like deliberate contrarianism, trolling, or naivete…): Will this change actually matter? Or do lots of PIs merely *think* it will matter? IIRC, under the old two proposal limit, not that many PIs or co-PIs actually submitted multiple proposals at a time (am I misremembering?). And very few PIs or co-PIs hold even two NSF grants at once. So are many PIs actually going to take up the opportunity to submit 2+ proposals per year, and is it actually going to make a big difference to their chances of getting funded? Plus, insofar as lots of PIs do take up the opportunity to submit 2+ proposals per year, doesn’t that just keep the average per-PI funding odds the same, but just create more work for reviewers and panels?

    I’m not suggesting NSF should’ve ignored the community’s demand for this change. I think it’s fine that they responded to the community’s feedback. I’m just trying to understand why the community was so insistent on this change.

    • As someone not in the US system currently and therefore only vaguely familiar with this, your comment was my immediate reaction as well. I think removing the co-pi limit might be good. People should not be prevented from collaborating on grants if their expertise is truly needed. But lead/solo PI limits seem very reasonable to me. Why should people be able to apply for several grants at once as a single/lead PI? I just do not understand why they didn’t start gradually by just eliminating the co-PI limit. If their claim is true, that they were doing this so that they didn’t “prevent collaboration”, eliminating just the co-pi limit is the better move, right?

    • My biggest concern about the limit was for pre-tenure folks. If you are in year 4 on the tenure track and don’t have funding yet, but have two proposals you’ve been working on (which would be pretty common for someone in that situation), which do you submit? NSF advised to focus on your strongest ideas, which makes sense, but assumes that you know which of your ideas *a panel* will view as strongest, which can be hard to predict.

      Since the limit was announced, I’ve had conversations with pre-tenure folks who were trying to figure out which proposal to put in — do you put in the one you led but that hasn’t been reviewed yet (meaning less of a sense of how it might fare) or the one with another PI that fared well in review in the past but where that PI already has funding (which might make them — and therefore both of you — less likely to be funded)? Now people don’t have to figure out those riddles. It might not be a big number of people in that situation, but the number is definitely greater than zero. And, if it is a small number, then what’s the harm in allowing it?

      A few summers ago, I submitted two proposals to the same program at the same time. I knew there was a 0% chance of them both being funded. But they involved different collaborators, and were on different concepts. It was especially hard to predict what the reaction would be to one of the two proposals — the manuscript that set up the idea had sailed through review at a really good journal, so there seemed to be some enthusiasm for the topic. But it also could be seen as very lake-oriented (which would be a kiss of death in an ecology panel). The other proposal was more in line with stuff we’d already been working on and more generally applicable in ecology, but more of an extension of earlier work. So, both because of an inability to tell which would be more exciting, and because they involved different collaborators, we submitted both. Again, we knew there was no way they would both be funded. But we decided it was still worth the effort to write both.

      Others have noted the impacts on collaboration. With NSF, if a proposal is going in through multiple universities, often there’s a PI at each institution. This is how it’s worked for all the collaborative proposals I’ve been on. NSF’s suggestion was that people like me (who, based on having tenure, don’t need to worry as much about getting credit for the grant) could be Senior Personnel. I don’t know how that works if the people aren’t at the same institution — maybe you’d be a subcontract (but then I think you get hit with overhead from two institutions)? I’m not sure how that would work, but hopefully someone else who does will chime in!

      • Thanks Meghan. This makes sense.

        Now I am curious how many pre-tenure folks will submit multiple proposals in the same year. I agree there’s no harm in allowing it. Just wondering.

      • It’s a moot point now that there are no limits on submissions as PI or coPI, but I don’t think the potential double hit on indirects to two institutions is a big deal. Only the first $25,000 of a sub award are subject to additional indirects. So, you could have a sub award of $500,000 to an institution with an IDC rate of 60% and the extra cost to the total budget of the grant would be $15,000. That’s not nothing, but it’s extremely unlikely to have any influence on whether or not the grant would be funded. Again, this is a moot point now, but who knows, it might be helpful info. Here’s some relevant language from NSF:
        Exclusions of Some Costs from Indirect Costs Recovery Calculations:
        The Federal government in general, and NSF specifically, does not permit indirect costs to be recovered on certain types of costs. Commonly excluded costs include:
        Equipment and capital expenditures
        The portion of subawards or subcontracts that exceed $25,000

    • Another group that I think the proposal limits had potential to harm are postdocs. Applying for major grants, even if unsuccessful, is a significant learning experience, and for a postdoc getting a grant funded has major career and personal life benefits (e.g., getting to do the research you want to do, building a research program that’s at least somewhat distinct from your mentors’, often getting to stay in the same place for more than just a year or two, often writing yourself into a grant means getting more than the standard minimum postdoc salary). But at many (most?) institutions, postdocs can’t be sole PIs on grants and need a collaborator with PI status to submit. Are there huge numbers of PIs that were facing a choice between another proposal they had planned and supporting their postdocs? Maybe not, but it’s certainly nonzero.

      • I had the same thought as Jon, and a Program Director I was chatting with a few days ago agreed that it could be an issue. The PD also told me that data (presumably from before these recent changes) show that the people on multiple grants have been almost entirely senior researchers. Thus the recent concerns about pre-tenure faculty being harmed by the PI cap are not supported by data on who submits more than one grant within each program.

      • It would be wonderful to see the data they have on who submits multiple proposals! Hopefully the subcommittee they form will be able to report out on those numbers.

      • Yes, I suppose it comes down not to whether pre-tenure folks are harmed by the caps, but whether they are more likely to be harmed than senior researchers. It would be really interesting to see data on that!

  2. I was surprised that they haven’t gotten a lot of proposals. I would have guessed that there would be a big pulse of initial proposals. It would be really interesting to know what factors are influencing when people submit (and whether some people held off on submitting wanting to not end up in a big deluge of initial proposals).

    • I’m guessing this has more to do with eliminating the deadline. It’s been observed pretty much every time a funding agency makes this move. Deadlines force you to submit your proposal! Without a deadline, you can always delay submission to make the proposal better.

      • Yes, I was expecting fewer submissions over the long term, but I knew people had been working on proposals while they weren’t accepting any, so thought it might be a bit like releasing a dam at first!

      • I had the same thought Matthew. Not surprised there wasn’t a big pulse of initial proposals.

        Though it would be funny if there wasn’t a big pulse of initial proposals only because everybody thought everybody *else* was going to submit a proposal at the earliest opportunity. #gametheory

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