"At the same time, the official NIH Grants Policy Statement says that a grant recipient “must obtain prior approval [emphasis in original] from the NIH” for a change in a grant’s scope, with the first example being a “change in the specific aims approved at the time of the award.” Other examples of prior NIH approval needed (there are many more): “substitution of one animal model for another,” “shift of the research emphasis from one disease area to another,” “changing assays from those approved to a different type of assay,” or “purchase of a unit of equipment exceeding $25,000.”"
This misunderstands the quoted section. All of the "examples" you list are not examples of a change of scope, but rather are *potential indicators* of a change in scope:
"Potential indicators of a change in scope include, but are not limited to, the following:
Change in the specific aims approved at the time of award.
Substitution of one animal model for another."
In practice, as Dr. Berg points out, this stuff is left up to the discretion of the PI and the program officer, and quite frankly the level of oversight is typically minimal. I've been doing biomedical research for over 15 years, almost entirely funded from NIH grants won by other principal investigators; for much of that time, the projects I focused on were of little direct relevance to the specific aims of the grants that funded my research, apart from being in the same general research area (virology). This has been an issue, and in fact we are far more careful about how we use industry funding, as it typically *is* in the form of an actual contract with specific deliverables.
The primary hard limit for NIH grants is on major equipment purchases (the $25,000 limit mentioned); this is because NIH grants are not intended to directly fund capital expenses (ie major equipment that will be used for many different projects over many years) as a rule; such expenditures are supposed to be covered by indirect costs.
Appreciate you publishing this. It would be refreshing if this convo was happening with current NIH decision-makers, but sadly it is not. I respect Dr. Berg greatly and appreciate the points of pushback and clarification.
the tom cech example is the whole argument: nih funded him to find a protein, he found something better, and they just said "cool." that flexibility is underrated
> I doubt many venture capital-style funders would have the patience necessary for these long and uncertain timelines.
The US government largely doesn't, either. The premise of government funding for science is that tax dollars should be used for things that aren't immediately profitable, such as basic research. But in practice, at least in the US, elected officials making top-level funding decisions are up for election every 2-6 years. It's in their short-term interest to keep every decision as a political football to score some advantage toward the next vote.
This is why I increasingly think that public science funding should be given as block grants to independent organizations with broad latitude.
"At the same time, the official NIH Grants Policy Statement says that a grant recipient “must obtain prior approval [emphasis in original] from the NIH” for a change in a grant’s scope, with the first example being a “change in the specific aims approved at the time of the award.” Other examples of prior NIH approval needed (there are many more): “substitution of one animal model for another,” “shift of the research emphasis from one disease area to another,” “changing assays from those approved to a different type of assay,” or “purchase of a unit of equipment exceeding $25,000.”"
This misunderstands the quoted section. All of the "examples" you list are not examples of a change of scope, but rather are *potential indicators* of a change in scope:
"Potential indicators of a change in scope include, but are not limited to, the following:
Change in the specific aims approved at the time of award.
Substitution of one animal model for another."
In practice, as Dr. Berg points out, this stuff is left up to the discretion of the PI and the program officer, and quite frankly the level of oversight is typically minimal. I've been doing biomedical research for over 15 years, almost entirely funded from NIH grants won by other principal investigators; for much of that time, the projects I focused on were of little direct relevance to the specific aims of the grants that funded my research, apart from being in the same general research area (virology). This has been an issue, and in fact we are far more careful about how we use industry funding, as it typically *is* in the form of an actual contract with specific deliverables.
The primary hard limit for NIH grants is on major equipment purchases (the $25,000 limit mentioned); this is because NIH grants are not intended to directly fund capital expenses (ie major equipment that will be used for many different projects over many years) as a rule; such expenditures are supposed to be covered by indirect costs.
Correction: "This has *never* been an issue"
Great to see dialogues like this. Thank you
Appreciate you publishing this. It would be refreshing if this convo was happening with current NIH decision-makers, but sadly it is not. I respect Dr. Berg greatly and appreciate the points of pushback and clarification.
Thanks! I know Jeremy Berg, but even if I didn’t, I’d be happy to engage with (coherent and well-written) critiques!
the tom cech example is the whole argument: nih funded him to find a protein, he found something better, and they just said "cool." that flexibility is underrated
> I doubt many venture capital-style funders would have the patience necessary for these long and uncertain timelines.
The US government largely doesn't, either. The premise of government funding for science is that tax dollars should be used for things that aren't immediately profitable, such as basic research. But in practice, at least in the US, elected officials making top-level funding decisions are up for election every 2-6 years. It's in their short-term interest to keep every decision as a political football to score some advantage toward the next vote.
This is why I increasingly think that public science funding should be given as block grants to independent organizations with broad latitude.