informing and reporting for review meetings document…  · web viewthe goal of the informing and...

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THE SCIENTIFIC REVIEW PROGRAM TRAINING PROGRAM (SRPTP) INFORMING AND REPORTING PROCEDURES May 2013 Disclaimer: The National Institute of Allergy and Infectious Diseases (NIAID) has made its training documents available to NIH review staff only as a service. In return for their use we request that you do not share or transmit any of the documents or training materials to anyone outside of the NIH. The NIAID does not guarantee the content of these documents to be correct or up to date. We do our best to keep these documents current. Documents are reviewed periodically or as needed. If you have any questions or comments, please contact us at [email protected] .

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Page 1: Informing and Reporting for Review Meetings Document…  · Web viewThe goal of the Informing and Reporting Procedures module is to provide guidelines and information for ... SOP:

THE SCIENTIFIC REVIEW PROGRAM TRAINING PROGRAM

(SRPTP)

INFORMING AND REPORTING PROCEDURES

May 2013

Disclaimer: The National Institute of Allergy and Infectious Diseases (NIAID) has made its training documents available to NIH review staff only as a service. In return for their use we request that you do not share or transmit any of the documents or training materials to anyone outside of the NIH. The NIAID does not guarantee the content of these documents to be correct or up to date. We do our best to keep these documents current. Documents are reviewed periodically or as needed. If you have any questions or comments, please contact us at [email protected].

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Goals for This Module Communicate expectations and procedures for the entire review meeting to relevant staff

members Make SRP staff members aware of important meeting logistics Communicate strategies of establishing timelines for pre- and post-review phases to staff Inform relevant Federal employees about the plans related to a review meeting Distribute general public notices Report meeting specifics and outcomes in the pre- and post-review phase via internal memos Provide procedures for reporting scientific misconduct Provide procedures for archiving documents after completion of a review meeting Communicate with SRP staff the process involved in handling Freedom of Information Act (FOIA)

requests, communications with registered lobbyists about Recovery Act funds, and appeal of scientific review of grant applications

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Acronyms Used in This DocumentAIDSRRC AIDS Research Review Committee IRG Integrated Review GroupAITRC Allergy, Immunology, and Transplantation

Research CommitteeIAR Internet Assisted Review

AO Administrative Officer LOI Letter of IntentARA Awaiting Receipt of Applications MIDRC Microbiology and Infectious Diseases

Research CommitteeBAA Broad Agency Announcements ND Not DiscussedBC Branch Chief OA Office of AcquisitionsBPA Blanket Purchase Agreement OER Office of Extramural ResearchCMO Committee Management Office ORI Office of Research IntegrityCO Contracting Officer PA Program AnnouncementCOI Conflict of Interest PHS Public Health ServiceCOR Contracting Officer’s Representative PIP Pre-Initiative PhaseCS Contracting Specialist PMOB Program Management Operations BranchCSR Center for Scientific Review PO Program/Project Officer (grants/contracts)DEA Division of Extramural Activities POC Point of Contact

RIO Research Integrity OfficerDMID Division of Microbiology & Infectious

DiseasesRFA Request for Applications

DAIDS Division of AIDS RFP Request for ProposalsDAIT Division of Allergy, Immunology &

TransplantationRIMS Research Initiative Management System

DRR Division of Receipt and Referral SEP Special Emphasis PanelEPOC Extramural Policy and Operations

CoordinationSRP Scientific Review Program

EPS Extramural Program Support SRS Scientific Review SpecialistER Electronic Review SPRS Secure Payee Registration SystemFOIA Freedom of Information Act SREA Scientific Review Evaluation ActivityFOA Funding Opportunity Announcement SRO Scientific Review OfficerFRN Federal Register Notice SSRO Senior Scientific Review OfficerGMP Grants Management Program TER Technical Evaluation ReportIAM Internet Assisted Meeting TESS Technical Evaluation Score SheetIC Institutes/Centers WTS World Travel ServicesIMPAC II Information for Management, Planning,

Analysis, and Coordination

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Table of Contents

Goals for This Module.................................................................................................................................. 2Acronyms Used in This Document...............................................................................................................3Introduction.................................................................................................................................................. 5

Federal Employees and Non-Federal Personnel Involved in Informing and Reporting Procedures.......5Phases of Informing and Reporting........................................................................................................6

Pre-Review Phase............................................................................................................................... 6Post-Review Phase............................................................................................................................. 6

What to Provide, When, and to Whom.........................................................................................................7Pre-Meeting Phase................................................................................................................................. 7

1. Prior to or at Receipt of Grant Applications/Contract Proposals......................................................72. Start-Up and Administrative Review................................................................................................93. Pre-Mailout Phase......................................................................................................................... 104. Federal Register Notice................................................................................................................. 145. Pre-Review Orientation Teleconference........................................................................................146. Reporting the Pre-Review Teleconference Roster for Reviewer Payment....................................157. Pre-Review Memo with Roster and Agenda..................................................................................168. Meeting Minutes............................................................................................................................ 16

Post-Meeting Phase............................................................................................................................. 179. Post-Meeting Score Release Memo..............................................................................................1710. SREA Report............................................................................................................................... 1811. Meeting Summary Statements/Technical Evaluation Report Completion Memo.........................1812. Reporting of Review Meeting Data in RIMS/ Post-Review Evaluations.......................................1913. Reporting Scientific Misconduct..................................................................................................1914. Archiving Meeting Information.....................................................................................................2115. Freedom of Information Act.........................................................................................................2216. Guidance Regarding Communication with Registered Lobbyists about Recovery Funds...........2217. Guidance on Appeals of Scientific Review of Grant Applications................................................22

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IntroductionClear communication is a key component of effective working relationships and facilitates high quality peer review. The goal of the Informing and Reporting Procedures module is to provide guidelines and information for communicating with internal NIH staff, applicants and reviewers during the pre-review, review, and post-review phases. Standard documents and procedures for communicating with applicants and NIH/NIAID staff members are presented in this module. Communication with reviewers is covered in depth in the Preparing the Reviewers module and, therefore, is not addressed in this module.

In the period leading up to the mailout, the Scientific Review Officer (SRO) and Extramural Program Staff (EPS) communicate frequently and keep each other informed about new developments that could affect established timelines. The SRO also keeps the Branch Chief (BC) informed of any changes in plans. The SRO and Program/Project Officer (PO) communicate frequently regarding reviewers, composition of the review panel, selection of the Chairperson, and scheduling of the review meeting dates. The SRO and the EPS communicate frequently with the Committee Management Office (CMO) regarding IMPAC II roster entries, and hotel and travel arrangements. The availability of the Grants Management Program (GMP) and Office of Acquisitions (OA) staff members and the BC are also considered during this process.

Federal Employees and Non-Federal Personnel Involved in Informing and Reporting ProceduresWithin SRP: SRO, EPS, BC, Program Analyst/Scientific Review Specialist (SRS), Senior Scientific Review Officer (SSRO), and Technical Writers

Within Division of Extramural Activities (DEA): OA, GMP (including coordinators listed in the FOA), CMO staff, and Director of DEA

Outside DEA: Program Staff (including coordinators listed in the FOA) from the Division of Microbiology and Infectious Diseases (DMID), Division of Allergy, Immunology and Transplantation (DAIT), the Division of AIDS (DAIDS), other NIH Institute/Center (IC) personnel, applicants, reviewers, and World Travel Services (WTS) staff

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Note: The headers for the different Informing and Reporting Procedures phases are linked to corresponding sections in the text. Click on “Back to List” to return to the initial phase list.

Phases of Informing and ReportingPre-Review Phase1. Prior to Receipt of Application(s)2. Start-Up and Administrative Review3. Pre-Mailout Phase4. Federal Register Notice5. Pre-Review Orientation Teleconference6. Pre-Review Teleconference Roster7. Pre-Review Memo with Roster and Agenda8. Meeting Minutes

Post-Review Phase9. Post-Meeting Score Release Memo10. SREA Report11. Summary Statements/TER Completion Memo12. Reporting of Review Meeting Data in RIMS/Post-Review Evaluations13. Reporting Scientific Misconduct14. Archiving Meeting Information15. Freedom of Information Act16. Communications with Registered Lobbyists about Recovery Funds17. Appeals of Scientific Review of Grant Applications

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What to Provide, When, and to WhomPre-Meeting Phase1. Prior to or at Receipt of Grant Applications/Contract Proposals

Back to List

Letter of Intent (LOI)/Proposal Intent Response Sheet (PIRS) Submission Phase A Funding Opportunity Announcement (FOA) may require a request for an LOI to be sent to review staff (grant applications) or a PIRS to be sent to OA staff (contract proposals). Although an LOI or PIRS generally is not required, is not binding, and does not enter into the review of a subsequent grant application/contract proposal, the information that it contains allows Institute/Center (IC) staff to estimate the potential review workload, plan the review and ensure that the work proposed by potential applicants/Offerors is within the scope of the FOA. During the LOI submission phase, SROs will receive inquiries from potential applicants and will need to address applicant questions regarding the content of the LOI, how to submit it (e.g., via email, fax or postal service) and the format of the LOI. Applicants responding to initiatives—Requests for Applications (RFA) or Program Announcements (PA)—will ask initiative-specific questions, e.g., whether the application can be submitted late, whether supplemental material will be accepted. The applicants may also ask questions about the budget, page limitations, when the Special Emphasis Panel (SEP) will be assembled, why the SEP cannot be found on NIAID’s website, and on which website the SEP information is available.

The SRO must decide whether the inquiries are review-related (requiring the SRO to respond), or if they should be referred to the PO. SROs may receive questions from Program staff on review-related issues on behalf of a potential applicant. The PO should respond to program-specific issues related to the initiative/FOAs. Clear and open, but mindful, communication among SROs, Program and NIAID/NIH or IC staff members and applicants at the pre-receipt phase is critical to ensure a fair and consistent review process when grant applications are finally received.

Before receipt of the LOIs and PIRSs, the SRO should make a request to the SRP Program Analyst to set up a Microsoft Access Database for the review meeting. After the receipt of LOIs and PIRSs, the EPS should enter the names of key personnel, their affiliation and other contact information into the MS Access Database (or into an MS Excel Database for a small number of grant applications). The SRO shares this preliminary list of key personnel and their institutions with the POs and other relevant staff. This information primarily helps to determine workload issues that may require the assignment of additional staff and/or the pre-recruitment of reviewers. Copies of the LOIs (hard or electronic) are provided to the PO for planning purposes, either individually as they are received, or as a complete set after the deadline. For contract reviews, SROs should request copies of the PIRSs received by OA staff from the Contracting Officer (CO) or Contracts Specialist (CS). SROs never contact Offerors for any information.

Application Submission

Applicants for RFAs and other grant submissions may contact the SRO about problems with submission to Grants.gov. SROs should direct the applicant to the Grants.gov Help Desk with any queries about submission. The SRO can also direct the inquiries to the NIAID DEA Extramural Policy and Operations Coordination (EPOC) staff ([email protected]). The applicants should be encouraged to submit at least one week before the receipt date since they are no longer allowed extra time to fix the errors. For allowable delayed submissions, the SRO should inform the SRP Program Analyst and NIAID Receipt and Referral Office and then initiate an Awaiting Receipt of Application (ARA) form electronically on the eRA Management and Solutions website as per the linked SOP: Initiate ARA in eRA). The NIAID Receipt and Referral Office is also notified via email and they alert the Center for Scientific Review (CSR) Division of Receipt and Referral (DRR) Officer. The NIAID Receipt and Referral Office submits the ARA form. CSR makes the final decision about late submissions. The SRO cannot grant or guarantee acceptance of a late submission to an applicant.

Panel Membership Requests by the ApplicantApplicants may sometimes suggest potential reviewers based on the expertise required for the SEP. In some instances, applicants also provide a list of reviewers who they request not to evaluate their grant applications. This request may be in the form of a cover letter that is posted in the Grant Folder at the eRA Commons/Internet

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Assisted Review (IAR) site together with the grant applications. This cover letter is only accessible to the SRO and not the PO. The SRO acknowledges the applicants’ input and may ask for a detailed explanation of the nature of the conflict. It is important to indicate to the applicants that there is no guarantee that their requests will be honored. The SRO consults with his or her BC to determine to what extent such requests should be considered and also the subsequent actions.

Receipt of Contract ProposalsFor contract proposals, when the SRO first receives the proposals (usually within two days after the receipt date), the Pre- and Post-meeting Document Delivery Form (see Pre-Post Meeting Document Delivery Form) must be signed and dated by the SRO and the CS, as indicated, and copies are retained by the SRO. The SRO relays this information to the SRP Program Analyst/Referral Officer, who will then assign the DEA and SEP numbers for the contract review.

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2. Start-Up and Administrative ReviewBack to List

To insure that the work is accomplished in a professional, timely, and efficient manner, it is important to outline expectations early in the process and to communicate with SRP, Program, OA and GMP staff, including Program and GMP coordinators listed in the FOA. Program staff members are a valuable resource for information. They can clarify programmatic priorities regarding the initiative being reviewed, provide information about potential reviewer conflicts that may not be readily apparent, and recommend potential reviewers. SROs should confer with Program and OA staff regarding their availability for attendance at pre-review teleconferences and review meetings. Contract review meetings cannot take place without the assigned CO (or another CO designated by the assigned CO) present in the room. Similarly, grants management and contract staff provide valuable advice and input regarding NIH policies and procedures related to the funding of grants and contracts, respectively, at the pre-review and review meetings. Thus, coordination with all parties involved is very important.

SRO and EPS Startup MeetingThe SRO/EPS team, in consultation with the BC, organizes the review meeting. Following the receipt of the applications/proposals, the SRO should set up a meeting with the EPS to plan the review with the following items in mind:

Make initial entries on the pre-meeting SRP planning worksheet (see Pre-meeting SRP Planning Worksheet). Send the planning worksheet via email to the BC, EPS, Lead EPS and the Program Analyst.

Relay the SEP number from the Referral Officer/Program Analyst to the EPS, confirm the assigned applications.

Discuss general expectations and features of the grant or contract review meeting; IAR for grant applications; Internet Assisted Meeting (IAM) and Electronic Review (ER) for contract proposals; whether some applications will be scored as Not Discussed (ND, previously called streamlining); pre-review teleconference; HiDef or Go to Meeting™; requirements for choice of meeting site (duration of meeting, number of reviewers and observers, any special needs, e.g., evening orientation, reverse site visit involvement of other NIH institutes, hotel preferences).

Establish a preliminary schedule for review. Determine target dates for the completion of the administrative review and conflict of interest (COI) list, tentative meeting dates, mailout window, and a target date for the completion of the documentation.

Share a meeting planning checklist with the EPS that includes approximate dates for achieving the milestones.

Give the grant applications or contract proposals and initial assignment of work (e.g., prepare COI list, prepare Technical Evaluation Score Sheet [TESS]) to the ESA with the expected due date for completion.

For grant applications submitted electronically, the SRO and the EPS decide which one of them will download the application images, abstracts, other related review materials, and appendix material from QVR or IMPAC II. These can be used for importing information into the MS Access database.

Request EPS to set up a series of folders on the R shared drive that the SRP review team will have access to for storing of all meeting materials. It is preferable to email links rather than documents.

SRP, Program, OA, and GMP Startup MeetingThis meeting must be scheduled by the SRO three to four weeks after receipt of grant applications/contract proposals. The SRO should remind all meeting participants (including coordinators listed in the FOA) to bring their calendars with them. If the administrative review of grant applications is completed and the SRO finds a grant application to be non-responsive, the SRO must alert the PO to read this grant application before the startup meeting. The meeting should include a discussion of the following topics:

Establish concurrence for the review timeline, collect information on staff availability and known external conflicting events (e.g., major scientific conferences/meetings in related fields, council meeting dates, holidays and religious observance days).

Ask Program/OA about any special issues the SRO should be informed about (e.g., any political issues with any PI or the initiative); any anticipated problems with the grant applications/ contract proposals,

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responsiveness to the FOA, reviewers or other issues, Pre-Initiative Phase (PIP) decision about Core scoring for complex application mechanisms, and programmatic goals to be achieved via the solicitation. For details on contract review, see the training module Introduction to Peer Review of R&D Contract Proposals.

Ask the PO if there is any reviewer who should absolutely not be on the panel and the justifiable reason for this statement (e.g., scientific dispute, etc.).

If necessary, solicit suggestions for panel members and Chair from Program, compile suggestions for reviewers, make COI list available, discuss expected number and type of reviewers needed and their sources (academic, industrial, federal, etc.).

Discuss any special issues anticipated, e.g., Not Discussed applications, IAR, IAM, teleconference, splitting into multiple SEPs, any new procedures to be piloted, waivers for contract SROs assisting the Lead SRO, contract OA staff attending the meeting.

Inform the PO about the topics that need to be addressed with the panel at the pre-review orientation meeting so that he or she can prepare for it. Follow up closer to the pre-review meeting.

Distribute the COI list for staff to sign if the COI list is complete before the meeting. Collect as soon as possible; perhaps at the pre-review teleconference.

Make adjustments on the Pre-meeting SRP Planning Worksheet and communicate the changes to concerned staff members.

Discuss with CO whether the SRO will write the Technical Evaluation Report (TER) in individual contract proposal segments.

Indicate to the PO that the standard way of summary statement preparation/TER is to follow the order of Overall Impact/Priority scores/ranking order (from best to worst) and ask if the PO has any other preferred order due to programmatic needs.

3. Pre-Mailout PhaseBack to List

Reviewer Manual/Critique Templates Request Soon after the completion of the administrative review of grant applications /contract proposals, the SRO should prepare the Reviewer Manual (in either PDF or HTML) by deleting links that are not applicable following the procedure on the SOP: Reviewer Manual. The SRO may contact the writers with a request for the preparation of the FOA specific critique templates from the standard Critique Template shell. It is important to select the correct critique templates necessary for the FOA/initiative under review.

Supplemental Materials/Post-Submission Application Materials

Grants: Since the application is written and submitted months before the review, a PI may have manuscripts that have been accepted for publication and sometimes requests the opportunity to send supplemental data/post-submission application materials (NOT-OD-10-115, NOT-OD-13-013 and NOT-OD-13-030. In consultation with the BC, the SRO should decide whether supplemental material will be accepted for an RFA. Note that if permission is given to one PI to submit supplemental materials, then the SRO should notify all PIs for that review in order to be fair and unbiased. The SRO may want to mention that supplemental data is optional/not required.

Acceptable supplemental information for FOAs with multiple receipt dates include: Revised budget pages (e.g., change in budget request due to new funding or institutional acquisition of

equipment) Biographical sketches (e.g., change in senior/key personnel due to the hiring, replacement, or loss of an

investigator) Letters of support or collaboration resulting from a change in senior/key personnel due to the hiring,

replacement, or loss of an investigator Adjustments resulting from natural disasters (e.g., loss of an animal colony) Adjustments resulting from change of institution (e.g., PI moves to another university)

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News of an article accepted for publication (a copy of the article should not be sent). Links to pre-submitted manuscripts that have been accepted by a journal

News of a professional promotion or positive tenure decision for any Program Directors/Principal Investigators and Senior/Key Personnel also will be accepted as post-submission application material.   The news must be received by the SRO one month (30 calendar days) prior to the peer review meeting, and demonstrate concurrence from the Authorized Organizational Representative (AOR) of the applicant organization.

News of promotions and professional achievements for trainees and faculty members on training grant applications; and

Post-submission materials for applications submitted for the last due date of a Request for Applications (RFA).

Page limits have been set so that this mechanism is not used as a way to circumvent page limits of the original submission.

The page limit allowed for explanation/letter is limited to one page, if post-submission material is not required on a form page

Supplemental/post-submission application materials that are not acceptable for FOAs with multiple receipt dates include:

Updated Specific Aims or Research Strategy pages Late-breaking research findings New letters of support or collaboration that do not result from a change in senior/key personnel due to the

hiring, replacement, or loss of an investigator

There are some exceptions to the policy for unacceptable supplemental materials:

1. Applications submitted in response to RFAs that have only one due date and those submitted to the last due date of an RFA with multiple due dates.:

Updated Specific Aims or Research Strategy pages, late-breaking research findings and new letters of support or collaboration will be allowed.

If additional material is not required on a form page, the page limits below apply:

Page Limit for Research Strategy Section

Page Limit for Post-Submission Materials

More than 12 pages 3 printed pages

12 pages 2 printed pages

Fewer than 12 pages 1 printed page

For a complex mechanism application with subprojects or cores, the page limits for supplemental/post-submission materials follow the page limit of the Research Strategy of each subproject or core, as shown above.

2. Certain NIH FOAs may allow specific other types of post-submission materials to facilitate the goals of the program as specified in the FOA.

3. Applications for institutional training and training-related grants only (T32 or T35 for NIAID), up to three pages

of the following items may be submitted as supplemental/post-submission materials as indicated in NOT-OD-10-104 : Updated information and data on:

applicant pool admissions enrollment

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appointments and/or achievements Updated faculty research support NOT-OD-13-030 lists acceptable post-submission materials for institutional training and training-related

grants [not fellowships (F series) or career (K series)] applications, including "appointments and/or achievements".  With this policy, the following types of information will be accepted:

oNews of a trainee's or former trainee's graduation, employment, promotion, funding, publication or other professional achievement since the training grant was submitted;

oNews of a faculty member's promotion, funding, publication, or other professional achievement since the training grant was submitted; and

oNews of an additional faculty member who will be involved in the training activity. 

Acceptable supplemental materials for other training-related activity codes (e.g., R25) must be specified in the FOA.

4. Videos, within defined limits, will be accepted as non post-submission materials (see NOT-OD-12-141 ).  Devices and other non-traditional materials will not be accepted after submission, unless the application is submitted for a Funding Opportunity Announcement that specifies other types of allowable post-submission materials.

5. If an application proposed to use a human embryonic cell line(s) that is approved by the NIH Stem Cell Registry at least 30 days prior to the peer review meeting, the SRO can include this update to the reviewers as part of the post-submission materials (see NOT-OD-12-111 ).  As per NOT-OD-08-082 (NOT-OD-10-115), acceptance of additional materials during the initial peer review phase is still at the discretion of the SRO.

Contracts: Supplemental data is not typically accepted for contract proposals. If there is a request, the CO must make the decision of whether to accept it or not.

Requesting additional information for deficient contract proposals (contract proposals lacking key sections): The FAR (https://www.acquisition.gov/Far/) specifically states that if only one contract proposal is received

for an RFP or a BAA, the SRO can request supplemental information for deficient contract proposals. If more than one contract proposal is received for an RFP or a BAA, the SRO cannot request additional

data from the CO.

Instructions for Naming a Meeting for the Public Domain

All grant application reviews should have the related FOA title as the meeting title. This title should also be used for entering the meeting/Panel Name in IMPAC II Committee Management module and would therefore be maintained as the meeting title on the publicly available roster. It is also the name that will be denoted in the Federal Register Notice (FRN). The numerous investigator-initiated P01 grant applications reviewed in each Council round appearing publicly will be distinguished by the ZAI 1 SEP number. If an SRO is running two review meetings with the same RFA title (e.g., two P01 grant applications) or running a contract proposal review with a split panel, the ZAI 1 SEP number can be modified slightly, e.g. ZAI1-XXX-M (M1) and ZAI1-XXX-M (M2) and ZAI1-XXX-M (C1) and ZAI1-XXX-M (C2) respectively as indicated in SOP: Meeting Title Instructions. If a review meeting involves more than one initiative, the individual titles are listed separately (e.g., Investigator-initiated Clinical Trials RFAs). For Charter Committee reviews, the Committee name and month and year for the review make up the title. An FRN request for a contract review meeting has the RFP/BAA announcement title available in the RIMS or on the admin review database menu as the title. However, when the FRN goes out, the meeting tittle is changed to “NIAID Peer Review Meeting” automatically in the system. Roster titles could be either the RFP/BAA title or “NIAID Peer Review Meeting” depending on the meeting title entered into IMPAC II. The names of the PIs, their degrees, the specific titles of their grant applications/contract proposals, and the number of grant applications/contract proposals to be reviewed must not be disclosed in publicly available documents.

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Important Guidelines for Naming Meeting Documents for Internal Use Only

Meeting documents for internal staff or reviewers, e.g., the pre- and post-meeting memos and meeting agenda can contain the specific grant application titles, PIs’ names and degrees, or grant application numbers.

Note: Information such as PI name(s) and specific titles of grant applications ARE NOT RESTRICTED from internal distribution among NIAID staff via our standard pre- and post-meeting memo notifications. Therefore, for internal memos, the use of the PIs’ names and degrees is required to facilitate communication.

Note: For contract proposal reviews, the names of Offerors must not be disclosed in the pre-meeting memos.

Roster and AgendaThe SEP meeting roster is entered into Committee Management module in IMPAC II and is available in the public domain from the OER web site, http://era.nih.gov/roster/index.cfm 30 days before the review meeting date. The meeting title that appears on the roster is the name of the FOA entered by the EPS when the meeting is set up in IMPAC II. The SEP number also appears on the roster. The roster is a publicly available document and therefore confidentiality about meeting specifics must be maintained (as described above). The roster for the Chartered Committees also can be found at the same site as the SEP rosters. Applicants might contact the SRO or PO to address any concerns when the meeting roster becomes available. For large and complex reviews that involve multiple SROs, only the name and contact information of the Lead SRO should be included on the roster, since he/she is the Designated Federal Official.

The agenda is available only to NIH/HHS staff and to SEP members, i.e. it is not a publicly available document. The meeting title on the agenda therefore should follow the naming instructions for an ‘Internal Use Only’ document (SOP: Meeting Title Instructions).

The roster and agenda are considered tentative and are usually finalized closer to the meeting or at the meeting. Many issues (e.g., emergency situations, health issues, newly discovered conflicts) can affect the roster composition and agenda.

Hotel and Travel ArrangementsShortly after the date for a face-to-face meeting is scheduled, the SRO works with the ESA to secure a hotel from the list of hotels on the BPA. These are hotels for which NIAID/NIH have already negotiated a government rate. The EPS will then obtain a contract with that hotel. More information about this process can be found in the SOP Meeting Hotel Contract Process. If it is absolutely necessary to use a hotel that is not on the BPA list, rates must be negotiated beforehand and approved by the NIAID CMO. A justification that includes two other hotel price quotes is required. The EPS requests for the Banquet Event Order (BEO) two weeks before the review meeting. Note that the BEO must no longer include charges for light refreshment as per the DHHS Light Refreshment Policy.

Note: To avoid incurring expenses for unused sleeping rooms, please adhere strictly to the cutoff date in the hotel contract for confirming the number of rooms required each night.

When the first panel members have been recruited (at least four weeks before the review meeting), the SRO reminds the EPS to provide the roster and updates to World Travel Services (WTS) preferably via email ([email protected]). The EPS should include their phone number in this communication. The SRO should be actively involved in this process and should request to be informed about or copied on all WTS communication with the EPS. The SRO also instructs the reviewers to make their reservations through WTS as soon as possible; this is frequently done before the mailout when the first reviewers recruited start asking about travel arrangements. The SRO should discuss any special issues with the WTS representative and any that involve extra costs must be approved by the NIAID CMO. If there is a medical reason for flying business or first class, the SRO must contact NIH Occupational Health to get confirmation of the reviewer’s disability and then the NIAID

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CMO, for approval. This process can take up to six weeks. The EPS initiates travel orders for Federal Reviewers and makes their travel arrangements through Omega World Travel, not WTS (see Travel Reimbursement for Regular Federal Employees). The SRO should pay particular attention to the travel arrangements of Federal reviewers. Notification of reservation and itinerary do NOT mean that the travel has been approved. This requires a travel order from the Administrative Officer (AO) after the reservations have been made. The travelport site will confirm whether e-tickets have been issued (https://www.viewtrip.com/). The SRO should be copied on all Omega communication (to and from the EPS) to make sure that travel orders have been issued before the meeting.

For the rare meeting that is held outside the local Maryland/Virginia area, Federal staff makes travel arrangements through Omega World Travel. The hotel reservations are made with the staff member’s government credit card/personal credit card, and the charges are reimbursed following the meeting, when the SRO submits a travel voucher. The cost of lodging for the reviewers and use of the meeting room is paid for by a WTS credit card. The SRO should contact CMO for this information a few days before the review meeting. Staff reservations can be followed on the Virtually There site (https://www.virtuallythere.com/) and on the TripCase mobile app).

4. Federal Register NoticeBack to List

See AI-PreMtg_Federal_Register_Notice_Fillable_Form.doc

The FRN is published by the Office of the Federal Register National Archives and Records Administration (NARA) http://www.archives.gov/federal-register/index.html

The Federal Register is the official daily publication for rules, proposed rules, and notices of Federal agencies and organizations, as well as executive orders and other presidential documents. It is updated daily, by 6 am, and is published Monday through Friday, except on federal holidays.

The Federal FRN request is sent via email by the EPS to CMO at least 30 days before the review meeting. This notice contains general information about the meeting that will become available to the public once the FRN is published. The FRN should contain the public title of the meeting. Naming conventions for the title are outlined in the linked SOP: Meeting Title Instructions. The meeting title should not include the name of an applicant, the grant application ID number, or the exact title of an investigator-initiated application.

5. Pre-Review Orientation TeleconferenceBack to List

Pre-Review Orientation Teleconferences are not permitted for single P01 grant application reviews. For these the SRO gives individual instruction to reviewers if needed. For RFA, RFP and BAA announcements, the SRO should notify Program and GMP/OA staff members of the date/time of the pre-review orientation teleconference to confirm their availability (including coordinators listed in the FOA). The roster and agenda for the orientation teleconference are attached to the SRO’s email message. The SRO should invite Program and OA staff to say a few words about the initiative to the review panel. This should not be a surprise to the PO or OA staff since they are informed about this in an earlier meeting. If the SRO is using a GoToMeeting™ online video platform, the SRO could invite the PO and OA staff to show PowerPoint slides at the orientation meeting. If you choose to do this, inform both the PO and OA staff that you will be giving a PowerPoint presentation and request copies of their presentations a week before the orientation meeting. Send the PowerPoint slides to the reviewers before the teleconference and keep a set of hardcopies available in case of technical problems. The GMP representative should also be invited to attend the pre-review meeting teleconference to give a presentation or to answer any budget questions especially for initiatives with complex budgets, subcontracts, etc. Audio should be provided by a service that gives Toll-Free numbers (GoToMeeting or HiDef). The workgroup is set up in Committee Management by the EPS and reviewers are reimbursed the mail reviewer’s rate. A SREA report is generated for payment.

Reporting the Pre-Review Teleconference Roster for Reviewer Payment

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After completion of the teleconference, the EPS generates the Workgroup SREA roster for the meeting. The SRO verifies the accuracy of the roster, signs it electronically by clicking on the box on the left hand side, and sends it via email to NIAID CMO. Reviewers who were not present at the orientation meeting are given the chance to listen to the recorded presentations and ask the SRO for any clarifications. They are then included on the Workgroup roster after certifying that they have listened to the recording (Teleconference Certification Template). The SOP for generating the SREA roster can be accessed via this link: SOP: SREA Roster Rpt and Payment. Reviewers will receive an honorarium of $100 for pre-review teleconferences. Please note that the SROs should no longer organize a pre-review teleconference for a single P01 grant application review.

6. SRP-Program/OA-GMP Pre-Review Communication to Prepare for the Peer Review Meeting:Back to List Upon completion of the pre-review teleconference, several issues may need to be addressed. The SRO may communicate primarily via email or phone with the PO/OA staff and/or GMP representative to address issues raised by reviewers after the pre-review teleconference and before the review meeting. The following topics may need to be addressed:

Review the agenda for the review meeting, indicating what the SRO and the Program/OA and/or GMP will address with the panel in the orientation remarks. These presentations may be similar to that for the orientation meeting.

Determine exactly who will attend and speak for Program, OA, and/or GMP and how much time will be required (adjust agenda and meeting folders accordingly)

Determine how many people/ who will be attending as observers from Program, OA, and GMP (to plan for how many folders and extra documents to have on hand, and whether contract staff members need to obtain waivers to attend)

Discuss the handling of any sensitive, tricky issues likely to come up, or those that have been raised by reviewers. If possible, plan to address such issues by incorporating information into the SRO’s or PO’s opening remarks at the review meeting.

Provide a consolidated questions and answers document from multiple pre-meeting teleconferences to staff and reviewers

Provide instructions for getting to the hotel, parking and restaurants at the meeting site, or other relevant logistics

Determine if there is any delay or if any amendments/questions and answers have been issued for clarification of the solicitation/RFP/BAA

SROs may provide Program/GMP/OA staff members with a password-protected CD containing grant applications/contract proposal PDFs upon request.

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7. Pre-Review Memo with Roster and AgendaBack to List

The pre-meeting memo should be sent via email to DEA, SRP, Program, GMP and OA staff (including coordinators listed in the FOA, see Distribution List) two weeks before the meeting date. The templates, along with distribution lists for grant or contract review meetings, are located here: Templates for Pre-meeting Memos. Memos for teleconference meetings, hotel meetings, IAM meetings, single project and multi-project meetings, and review meetings for all initiative FOAs, i.e., RFA, RFP, BAA, or investigator-initiated, vary.

Note: All memos that will be distributed internally must be reviewed and approved by the SRO before circulation via email to relevant Federal staff. On the rare occasion where a revised memo is necessary, a brief sentence may be added to the subject line of the email alerting the recipients of the revision.

8. Meeting MinutesBack to List

Meeting Minutes are one page documents reporting the basic meeting information, e.g., the number and types of applications, the total dollar amounts requested for the entire award period, date of review meeting, and the official time the meeting was adjourned.

The accessing and signing process for Meeting Minutes is similar for grant application and contract proposal review meetings:For grant application reviews: The Chairperson and SRO sign the Meeting Minutes electronically at the eRA Commons/IAR site at the end of the meeting. The signed minutes can be accessed by NIAID CMO directly.

Within two days, the SRO delivers the SREA report also electronically to the NIAID CMO (see the SOP: SREA Roster Rpt and Payment) and Post-Meeting Documents Required by NIAID CMO.

For contract proposal reviews only: The paper copy of the signed Meeting Minutes is sent to NIAID CMO as a backup.

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Post-Meeting Phase9. Post-Meeting Score Release Memo

Back to List

A. Grant Application ReviewFor grant application reviews only, the post-meeting memo is distributed within five business days after the review meeting. The EPS prepares the post-meeting memo with guidance from the SRO and sends it to Program, DEA and SRP staff using the distribution list (see Distribution list and template memos in the Informing and Reporting folder). A Composite Score sheet for all grant applications, including those that were not discussed, is attached to the memo and scores are listed from best to worst. Prior to the distribution of the post-meeting memo for grant application reviews, the following actions need to be taken:

Scores need to be released in the peer review module of IMPAC II. This allows the generation of the composite scores sheet. SROs should alert program of the score release since PIs are able to view their scores immediately upon release and will contact the PO. SROs may also receive phone calls and email messages from PIs once the scores are released.

The meeting needs to be released in the peer review module of IMPAC II. This step requires that Expertise codes and Special Issues codes (human subjects, vertebrate animals, and clinical trials) are entered in IMPAC II by the EPS upon receipt from the SRO. New reviewers need their expertise codes entered using the list of expertise codes generated from IMPAC II. SRP also keeps its own list of IMPAC expertise codes. Therefore, as reviewers are recruited, it is advisable to enter expertise codes to avoid delays in releasing the meeting in IMPAC II after completion of the review meeting. Expertise codes and Special Issues codes are not required for release of scores.

The roster needs to be released in IMPAC II for attachment to a released summary statement. Once the meeting is released in IMPAC II, the summary statement drafts can be uploaded and the final

summary statements can subsequently be released after the SRO has proof-read the drafts. The SRO should refer the applicant to the PO for questions on post-meeting issues regarding funding

decisions, what the score means, etc. Questions on the release of the summary statement are addressed by the SRO.

Note: If the review meeting was split into more than one meeting, the SRO should not release the scores in IMPAC II until all the meetings are completed.

Note: In IAR, under the control panel, there are several options for the initial creation of the pre-summary statement zip file that contains the reviewer critiques for a particular application. This pre-summary statement option is used for both manual and macro-driven concatenation of the summary statements. The options are: “When the submit phase is over,” “When the read phase is over,” “When the edit phase is over” and “When meeting is released in peer review.” Checking the option “When the meeting is released in peer review” on the IAR control panel prevents the accessibility of the IAR pre-summary statements. However, do remember to change the option back to the IAR preferred default, “When meeting is released in peer review” as this can cause a backlog in summary statement concatenation (also see the IAR training module).

Special Circumstances for Grant Application Review If the initiative is reviewed in two or more SEPs the scores are released at the end of the final meeting

simultaneously. These scores may be released in a single memo with a combined composite score sheet or multiple composite score sheets attached, or using separate memos for each SEP meeting with its own attached composite score sheet. If a single memo is used to report the scores, the wording in the body of the memo should be altered since there is no existing template for it.

The Program Officials’ Report (located in Peer Review under Reports) for the Microbiology and Infectious Diseases Research Committee (MID) Charter Committee meetings is also attached to pre- and post-meeting memos. This is specific for MID and MID B committees, which typically have many POs assigned to the grant applications under review.

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B. Contract Proposal ReviewThere is no immediate public or internal announcement of the contract proposal scores following a contract proposal review meeting. OA staff enters the scores on an Excel worksheet during the meeting and uses this score sheet to notify concerned parties (CO, CS, BC, SRO, BC, and PO/Contracting Officer’s Representative [COR]). The SRO should also independently add up the scores from reviewers’ TESSs and compare them to those entered by OA staff. Upon request, the CO can provide Offerors with their scores after the awards are made. Only COs are permitted to communicate with the Offeror’s institution.

The SRO checks the scores on the Excel worksheet and provides contract staff with any corrections. The SRO uses a copy of the TESS form to write the Technical Evaluation Report (TER). The SRO/EPS

should give the original TESS forms to the OA staff and only keep copies. Following the meeting, the SRO prepares the TER. The TER is an internal document that contains the

scores on the face page and at the top of each Offeror section. It is used by COs and POs to compile questions to the Offeror for the negotiations and for debriefing feedback if requested by the Offeror.

The TER is delivered to OA staff no later than 120 days from receipt of the contract proposals (see details in Section 11 below).

10. SREA Report Back to List

After the completion of a teleconference or a face-to-face review meeting, the EPS generates the SREA roster for the meeting and follows the procedure in the SOP: SREA Roster Rpt and Payment. SROs must identify and explain any other reviewer travel or attendance issues that do not fit any of the specified categories/columns in the SREA report in the Exceptions/Comments column. Examples of such comments:

If a local reviewer stayed in the hotel or not (the codes are L and L/N—local and Local/not staying in the hotel)

Reviewer is a mail-in reviewer Reviewer drove to the meeting from a particular city (mileage and tolls helpful to include) Reviewer declined honorarium and include the reason for the decision Reviewer bought own ticket (EPS/SRO may reference email to CMO about this action) Reviewer is a Federal employee serving on personal time. This is only for VA employees who can claim

university appointment time to claim payment through SREA as opposed to a government travel authorization.

Reviewer working at a federal agency but as a contractor

NIAID CMO requests more details in the Exceptions/Comments column to be able to reimburse reviewers more accurately and reduce the number of calls to reviewers for clarifications. More details in this column will also facilitate cross referencing information in other sections of the report. Note that entering comments will change the reimbursement due to Not Applicable (NA) although it will not impact reimbursement. See also PostMtg_Docs_Required_by_NIAID_CMO.doc

11. Meeting Summary Statements/Technical Evaluation Report Completion MemoBack to List

Grant Application Review: Immediately following the completion of all the summary statements for a grant application review, the

SRO’s BC and PO for the initiative may be notified by email that the summary statements are available on eRA Commons/IAR for viewing by the applicant(s). Alternatively, for meetings with a large number of applications, the summary statements may be released in the order determined by Program and the SRO based on the funding plan.

For a meeting with a large number of grant applications, a weekly notice of completed summary statements may be sent to the SRO’s BC and PO (optional).

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Contract Proposal Review: Contract proposal reviews require in-person delivery to the CO of the hard copy of the TER, the original

pre- and post-meeting conflict of interest forms and the meeting attendance sheet. The back pages of the TER include the roster and the meeting summary.

The final hard copy of the TER is hand-delivered to OA staff (usually the CS) with the SRO’s original signature. The OA staff receives the signed TESSs, original COI forms from reviewers and staff, meeting minutes signed by the Chair and the SRO (this is a different document than the last page of the TER), roster, agenda, sign-in sheets for face-to-face meetings, COI waivers and Notes to the Record. A Document Delivery Form is signed by OA staff for confirmation of receipt.

The Document Delivery Form records the delivery of the TER and also the number of days between receipt of the contract proposals and delivery of the TER, which should be less than 120 days. This document should be retained by the SRO for two years to verify/confirm prompt delivery.

The post-meeting memo, in the form of electronic copies of the TER (both Word.doc and .pdf formats), are distributed to the following individuals per the Standard Distribution List: CO, CS, assigned SRO, and appropriate BC.

12. Reporting of Review Meeting Data in RIMS/ Post-Review EvaluationsBack to List

On completion of a review meeting for an RFA, RFP or BAA, the SRO enters the information on the NIAID initiative data collection form (NIAID Initiative Data Template) directly into Research Initiative Management System. (RIMS). SROs responsible for P01 grant application reviews should give their completed NIAID Initiative Data Template to the SRP Program Analyst for combined entry into RIMS. For Charter Committees K and T; LRP, R13, etc. review meetings, the NIH Initiative data collection form is completed by the SRO and then forwarded to the SRP Program Analyst for combined entry into RIMS. The SRO provides the Summary Statement/TER completion date when these are completed.

SROs should send all post-review evaluations to their BC for approval before forwarding them to the SRP Program Analysts for posting in RIMS.

See The Research Initiative Management System (RIMS) SRP Module Guide for more information.

13. Reporting Scientific MisconductBack to List

“Misconduct” or “misconduct in science” is defined at 42 CFR 50.102 as fabrication, falsification, plagiarism, or other practices that seriously deviate from those that are commonly accepted within the scientific community for proposing, conducting, or reporting research. It does not include honest errors or honest differences in interpretations or judgments of data.

If reviewers suspect misconduct, they should contact the SRO immediately and should not wait until the review meeting (see Preparing the Reviewers training module).

If the scientific misconduct is discovered during the review, the general principle is that the review proceeds if the scientific review group is able to provide an unbiased technical/scientific merit review that is unaffected by the suspicions of misconduct. If it is determined that a fair review of an application cannot be carried out by the initial review group because of the existence of reviewers’ concerns about possible misconduct, immediate deferral of the application is the correct course of action.

In either case, the concerns of the scientific review group will be subsequently forwarded by the SRO to the BC, who will forward the concerns to a Research Integrity Officer (RIO), if necessary.

It is important that reviewers appreciate the seriousness of such allegations and the potential harm that may result if confidentiality is not strictly maintained. In no instance shall the SRO or a reviewer communicate the scientific review group’s concerns to the Program Director/Principal Investigator or applicant institution. Any subsequent communications with the Program Director/Principal Investigator and/or applicant institution will be done only through the ORI.

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The NIAID SOP for Research Misconduct Cases can be found at the following website:http://www.niaid.nih.gov/ncn/sop/misconduct.htm.

Research Integrity OfficersResearch Integrity Officers are institutional officials who have responsibilities related to the handling of allegations of research misconduct involving biomedical or behavioral research or research training supported by the Public Health Service (PHS).

More information on the Office of Research Integrity can be found at the following website:http://ori.dhhs.gov/misconduct/reg_subpart_a.shtml

A list of Research Integrity Officers can also be found at the following website:http://ori.hhs.gov/rio/

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14. Archiving Meeting InformationBack to List

Every time a SEP review meeting is completed, whether for grant applications or contract proposals, a number of important and sensitive documents are archived (see PostMtg_Archival_Checklist). This is largely accomplished by the EPS, who routinely take copies of such documents to SRP’s Program Analyst. This must be done any time before the council round is completed for grant applications and within 120 days after the receipt of contract proposals. The original TESS documents are NOT archived, but are given to the CO/CS. The SOP PostMtg_Review Document Retention.doc contains detailed information on archiving of meeting related documents post review.

Note: In some instances, completed meetings are audited and these archived files are retrieved for detailed inspection of the required documents.

Archival Documents to provide to Program Analyst: Roster Agenda Minutes (or last page of TER for contract review) Sign-in sheets Signed pre- and post-review conflict of interest forms for reviewers and staff Waiver approvals obtained for OA or Program Staff conflicts Notes to Record Ban on Lobbyist form OFACP Form

Note: “Notes to Record” or “Waiver Approvals for Contract or Program Staff Conflicts” should be given to the EPS so they can include them in the delivery. All original TESS forms should be given to the EPS so they can deliver it to the CS/CO soon after the meeting. SRO keeps only copies of TESS forms and Confidentiality Certification forms for 180 days.

ComplianceSince all of the above-mentioned documents and materials are archived, to be compliant, SRP staff should not maintain the original TESS or most of the documents for a grant review after Council or for a contract review after the award has been made. These include the SRO’s notes that were used to generate the Resume and Discussion section of the summary statements or other parts of the TER.

However, the two documents that may be stored on the R: drive are: Rosters, since they are publicly available A list of reviewers with publicly available personal information and respective expertise

Note: The privacy of reviewers should be maintained.

Boilerplate/template email messages can be saved in non-meeting specific folders under R:\SRA or on the H: drive.

Original applications and assignment lists should be disposed of, or promptly deleted from the SRO’s meeting folders on the R: drive folders.

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15. Freedom of Information ActBack to List

The Freedom of Information Act (FOIA), section 552 of title 5 of the United States Code, allows individuals to request and obtain information on the operations of federal agencies. All federal agencies, including NIAID, must make their records available to the public, unless the records (or parts of the records) are protected from disclosure by any of the nine FOIA exemptions.

On January 4, 2007, the US Congress enacted the ‘‘Openness Promotes Effectiveness in our National Government Act of 2007,’’ or the ‘‘OPEN Government Act of 2007,’’ to strengthen FOIA with amendments that intended to make agencies more compliant with FOIA requests by addressing “a range of procedural issues impacting FOIA administration.” No changes were made to the nine exemptions. http://www.usdoj.gov/oip/foiapost/2008foiapost9.htm

Agencies can be penalized if they do not respond to requests within 20 working days. The penalties include fines, attorney fees, and employee disciplinary actions.

Staff members will need to act quickly on FOIA requests/issues Another amendment will allow requesters to file a lawsuit against NIH in federal court, claiming

“constructive denial” if NIH does not respond to their requests within the 20-day timeframe

Freedom of Information Act RequestsSometimes SRP staff members may receive requests for information about an initiative or review from other NIH ICs, the NIH Director, other Federal Agencies, community activists, reporters, lawyers, researchers, investigators, and a myriad other sources. These requests may be made at any time (e.g., after release of an initiative or the FRN for a review meeting), by phone or by email.

Note: Do not get caught off guard in the middle of your busy day and respond to questions or requests without following proper procedure! Do not answer any probing questions from anyone, no matter how simple they may seem!

Handling Freedom of Information Act RequestsThere are special procedures for handling FOIA requests. First, ask for the requesters’ full names and contact information and tell them that they will be contacted by management. Immediately contact and inform your BC.

NIH Freedom of Information Act Office http://www.nih.gov/icd/od/foia/index.htm FOIA Information for NIH Staff http://www.nih.gov/icd/od/foia/nihonly/forms/forms.htm

Note: It may be necessary to contact many other people for a response to be put together—e.g., NIAID staff from other Divisions, grantees and contractors (to find out what may be proprietary in an application or proposal), other NIH staff, etc.—so acting quickly is critical.

16. Guidance Regarding Communication with Registered Lobbyists about Recovery FundsBack to List

All inquiries that SROs may receive by phone or email regarding communications with registered lobbyists should be forwarded to the NIAID Office of Communication and Government Relations (Contact: Branch Chief, Legislative Affairs and Correspondence Management Branch) by their BCs. The current guidance document for this issue is found in this link: http://www.whitehouse.gov/sites/default/files/omb/assets/memoranda_fy2009/m09-24.pdf.

17. Guidance on Appeals of Scientific Review of Grant ApplicationsBack to List

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The NIH policy for appeals of initial NIH peer review was initially revised in NIH Guide Notice NOT-OD-11-064 and OER Policy Announcement 2011-01. The NIAID website (http://funding.niaid.nih.gov/researchfunding/sop/pages/appeals.aspx) provides a guidance document on how to handle appeals of scientific review of grant applications to both program and review staff. As an SRO the following suggestions are recommended:

Notify your BC when you learn of a potential appeal. Gather all pertinent information remaining in your files. Work with your PO to resolve appeal requests. Discuss with reviewers, if appropriate, and provide the Appeals Officer with any comments from them. Write the SRO response letter in consultation with your BC. Attend Council meeting for cases that proceed on for Council considerations, and be prepared to address

review related issues related to the appeal.There has been a recent OER revision of the appeals policy especially as it relates to SROs in the OER Policy Announcement 2012-02 (05/22/2012) (http://nih-extramural-intranet.od.nih.gov/nih/policies/oer_announce_2012_02.htm) that elaborates on what needs to be included in the SRO response letter. The SRO response letter should:

1) document that the SRO has been informed of the appeal, 2) allow the SRO the opportunity to provide information for program staff and Council members from the review perspective, 3) protect confidential information about peer reviewers, and 4) ensure consistency in practice across the agency. The additional policy applies to the initial peer review of all applications submitted to the NIH for the May 25, 2012 due date and thereafter (January 2013 Council).There should be strict confidentiality regarding assigned reviewers for the application appealed, their scoring behavior, their financial holdings or other conflicts, which reviewers were recused from parts of the review.

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