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Dr. Richard Nakamura is director of the NIH Center for Scientific Review.
Today we’d like to start with a little scenario:
Kevin is a principal investigator whose application is undergoing peer review. At a national research symposium, he bumps into one of the reviewers on the study section that is evaluating his application. What should they do or say?
The answer: talk about anything but the application. Since Kevin’s application is under review, he and the reviewer must always avoid discussing the application during the peer review process.
NIH takes great measures and sets standards to provide a venue for fair competition and preserve the integrity of the peer review process. It is essential for everyone involved in the peer review process — investigators, officials of applicant organizations, reviewers, as well as scientific review officers (SROs) — to uphold these standards.
We understand that professional interactions need to continue while your application is undergoing peer review. However, as a PI, you cannot attempt to influence the outcome of the review (your SRO should be your only official contact to the review process). You cannot provide new information or data on your application directly to reviewers (again, contact your SRO and follow NIH policies for submitting post-submission materials). You also cannot contact reviewers to get your scores or critiques.
We greatly appreciate the many who follow these guidelines. But for those who breach this trust — and thankfully there are very few! — understand there can be serious consequences to your actions.
If NIH determines a fair review cannot be conducted due to applicant activities that violate these peer review standards, NIH can defer or withdraw the application. Depending on the circumstances, NIH can also take further administrative actions and may notify the PI’s institution regarding the incident.
Likewise, reviewers must maintain strict confidentiality about the peer review process. Reviewers cannot share applications with colleagues, students, or anyone outside of the review meeting. They cannot disclose confidential information discussed at the review meeting with others not involved in the meeting. Additionally, they cannot allow anyone access to NIH peer review electronic systems. If any of these events occurs NIH will take action to remove the reviewer from the peer review process, or take further actions. For further information, please see a previous Rock Talk post.
Today we’ve issued a new NIH Guide notice reminding applicants of the importance of their responsibilities in maintaining integrity in peer review. We also encourage you to review our updated website, “Integrity and Confidentiality in NIH Peer Review” for more information, and to share these resources with your colleagues and trainees, especially those who might be new to applying to NIH.
We all share the same objective: ensuring a fair review, free of bias, so that the most meritorious applications are identified for funding consideration by NIH. The peer review system belongs to the entire biomedical research community, not just to NIH — let’s do all we can as a community to preserve its integrity.
“Talk about anything but the application” is far too broad a statement. Conferences are for talking about science. Science is in the application. Can you only talk about science that isn’t in an application under review? What if you are there to present work that is included in the preliminary data of a grant application? Do you have to ask reviewers to leave the room? It’s understood that you should never talk about the review process itself, but this is a much more limited stricture than not “talking about the application.” Are you not allowed to discuss a criticism that was mentioned in a grant review? This doesn’t make any sense. You need to be able to talk about your work and the feedback you’ve received in a completely open manner. To do otherwise is dishonest and unethical. It would be more helpful if this article were more clear about what “fair review” and “free of bias” really mean. The sanctity of the review process does not trump the open exchange of information and ideas.
Just to riff off your scenario of running into your colleague who is on the study section reviewing your grant at a conference: You are certainly entitled to discuss any scientific topics you want with this reviewer, including describing new experiments you have done in your lab that are germane to the grant application under review, so long as you do not refer specifically to the grant or its review, correct?
Is the summary statement a confidential document or can one share it widely?
In a related vein, is the summary statement subject to FOIA? What about applications that have not been funded?
One thing that could alleviate the desire to update the reviewers of new results is to allow a one page update on an application prior to the review. A brief description of new data that could not have been obtained prior to the original submission (A scheduled beamtime at a synchrotron or free electron laser facility for example) could be beneficial to the reviewers, the PI and the NIH, as it would make the application more comprehensive. The present policy of no updates is a disservice to all.
“Integrity and Confidentiality in NIH Peer Review” What about the SROs who do not
exercise “Integrity’?