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Your comments on our peer review integrity case studies suggest that you found them informative, engaging, and thought-provoking. The Professional Grant Writer and Asking for Favorable Treatment examples were in the Top 10 read Open Mike posts of 2021 and 2020, respectively. The success of the series prompted us to expand them beyond solely peer review and address other areas of research integrity. Today we discuss what you and your institution should consider when submitting the same applications to multiple funders. As always, the goal is to raise awareness, encourage dialog and inspire creative problem solving to ensure integrity in NIH-funded research.
As with the peer review case studies, this event reflects a real-life situation. Names and identifiers have been changed or removed.
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Dr. Doe has a great research idea and wants to maximize the success of their application, identifying NIH and another federal agency as possible funders. Together with the institutional grants office, they work to prepare two nearly identical applications and have them submitted to both federal agencies, hoping at least one will fund it.
No problem, right? There is no NIH policy against sending the same application to us and another funder at the same time, you might argue. That may be true, but it is also true we have policies in place that require disclosing when scientific overlap exists in separate applications, especially those pending support.
The other funder found the application meritorious and approved it for funding. NIH, separately, did the same later. Importantly, Dr. Doe and the institution certified in the Other Support section that “no overlap” exists between the two applications.
This meant that the U.S. government funded this project twice. Neither Dr. Doe nor the institution chose to inform us about the two identical applications and the duplicative funding decisions.
One of the roles for the institution’s Signing Official is to assure us that the information provided in their application is “true, accurate, and complete to the best of the PI’s knowledge” (see NIH Grants Policy Statement Section 2.3.7.6). When an applicant knowingly affirms on their Other Support section that no scientific or budgetary overlap exists between virtually identical applications submitted to different funders, they are being dishonest.
How did we figure it out? Remember that software used in college that sifts through papers looking for plagiarized text? We apply that same concept to grant applications submitted to NIH for funding, along with those submitted to some other federal funders.
We found grants from the NIH and another federal agency linked to Dr. Doe and their institution had nearly identical text. They were virtually the same project. Then, while looking at what was specified in the Other Support section for both applications, we clearly saw that the applicant cited the other application and wrote falsely that there was “no overlap.”
We reached out to the institution’s Vice President for Research to share our findings. The overlapping segments of both grant applications clearly identified they were virtually the same. Faced with this evidence, the recipient institution agreed with our findings of duplicative funding and decided to take appropriate steps. NIH took appropriate administrative action to address the noncompliance and was able to recover funds.
We consider these episodes as “never events”; they simply should not happen. Unfortunately, this is not the only example. Here are some ways you and your institution can prevent this going forward:
- Improve internal institutional controls, such as running your applications through plagiarism software to identify duplication and handle it appropriately before submission.
- Remind staff that when signing the Other Support forms, they are attesting to the fact their applications are true, accurate, and complete. It is not a mere formality or paper exercise. And there are victims; outstanding grants from other applicants are left on the table when NIH makes an ill-informed duplicative funding decision.
Keep this in mind when applying for NIH support. Remember, while we allow submission of identical applications to separate federal agencies, we require that the overlap be disclosed. However, note that we do not allow identical applications be submitted to separate NIH Institutes, Centers, or Offices (see the NIH Grants Policy Statement and our submission policies page). Just like we encourage institutions to put internal controls in place, we also have put into place such controls to prevent us from funding the same application twice within and outside NIH.
Duplicative funding is a loss for biomedical research. It is a misuse of taxpayer funds. Another meritorious idea and researcher failed to be funded because of it. There is a lesson in here for all of us.
I’ve known PI’s to have varying levels of knowledge about this, so what appalls me about this story is that apparently the Grants and Contracts department did not notice this duplication. Apparently, the applications were pretty much identical, yet that department allowed them to hit “submit” on both of them. This suggests oversight is not what it needs to be if we are going that organization that much taxpayer money. I’d want to cut a place like that off altogether.
Sadly I think many Grants and Contracts departments at major academic institutions are suffering from gross understaffing like many other companies/businesses which is leading to unfortunately these things slipping through the cracks.
It is my impression that essentially the same proposal may be submitted as a project on a multiple project proposal and as an R01, although overlap must be acknowledged and the two proposals cannot both be accepted. Is this impression incorrect?
Our policy for overlapping applications is explained in NOT-OD-18-197 and indicates an individual research project identical to a subproject that is part of a multi-project application such as a program project or center grant application can be under review at the same time. You may want to reach out to the scientific contacts on the funding opportunities to discuss any nuances.