There have been substantial changes at NIH since the new administration came to power, and many of them have to do with how NIH funding is allocated. Amidst all the rapid-fire changes that have caused significant chaos and turmoil, it can be hard to navigate the landscape and determine which changes are merely disruptive, which have potential to derail the enterprise, and which ones could actually benefit science. As a former director of extramural operations for an NIH Institute, I would like to weigh in on the Unified Funding Strategy (UFS), which has raised concern from the community, and discuss the recent webinar describing this strategy.
Here is some brief context before I get started (if you know how the NIH systems works you can skip this paragraph). Before this administration, each NIH Institute and Center (IC) set and published their own funding strategy. Some ICs published payline, which was the score cutoff that determined whether an application would get funded or not. In the NIH scoring system, lower scores are better, so when budgets were tight, paylines were low, when budgets increased, paylines could be higher meaning more applications would get funded. This provided clear and transparent guidelines for applicants and for those making the funding decisions. However, not all ICs used paylines to make funding decisions. Other ICs used a more flexible approach that is similar to the current UFS. So, the change here is that rather than having each IC decide their own strategy, there is now a mandated top down approach that everyone must use, meaning some ICs and their recipient communities will have to adjust to operating differently than they have in the past. This is not in itself a bad thing, but I do have some concerns with how this new policy is being implemented and how it is being presented to the community.
First of all, let me say clearly that I am not opposed to a strategy that takes things other than the raw impact score of an application into consideration when funding decisions are being made. As stated above, this has always been the case. Many institutes and centers (ICs) did not have a payline in the past, and even at ICs with paylines, there were mechanisms in place for exceptions to be made. These exceptions could be to fund a new investigator, a new institution, a new and exciting idea that didn’t score well because it had not yet been tested, or a wide variety of other reasons. There was also latitude to make decisions not to fund something even though it scored well if that investigator, institution, or area of science was already over-invested. Each of these decisions to fund something that did not score as well (or “reach” for an application out of score order), or not to fund something that scored quite well (or “skip” an application in score order) required a justification memo that was signed by the program officer and the division director and kept in the grant folder. This was for accountability and transparency, so these decisions were documented as having a scientific reason, not an arbitrary, political, or personal one.
Program Officers have always taken the reviewer’s comments into consideration when making funding recommendations, listening to the actual review whenever possible and referring to other listener’s notes and the summary statements when they could not listen to the review themselves. Hearing and understanding the nuances of the review discussion and understanding their implications for programmatic balance and for scientific advancement is part of the job of a program director. Making funding recommendations that balance the portfolio, push the bounds of scientific knowledge, and provide opportunities to new investigators and new institutions is also part of the job.
Trying new things and spreading the wealth to under-funded areas geographically, scientifically, or demographically is not new to NIH. It was the impetus behind much of the diversity programming that was gutted by this administration. The idea of high risk, high reward science is not new and many past and current NIH programs have had that goal. However, successfully implementing efforts to fund more good science and more promising investigators in more places does not happen overnight or at the stroke of a policy pen. The claim that the UFS is being implemented to solve these problems is suspect, at best. People doing the work and people impacted by the change have not been consulted in the implementation planning, and as far as I am aware, no evaluation plan has been proposed to determine if the changes achieve their stated goals. In fact, it is not clear that measurable outcomes have even been clearly defined or considered.
So, let’s talk about the webinar and some of the details that were stated, as well as what was missing. I think the most deceptive statement was that IC Directors (ICD) will make the final funding decision. In the past, this has been true, the ICD has the final sign off on all funding recommendations from program staff before going to grant management (where the Chief Grant Management Officer, CGMO, was responsible for the final sign off on awards being made). Now applications go through further screening by OER and apparently sometimes HHS and maybe even OMB after the ICD and CGMO have signed off but before they actually get funded. This was not mentioned once in the webinar.
There was also a lot of talk about relying on and talking to program staff who attend the review meetings and obtaining the required feedback from the summary statements written by the scientific review officers. These are indeed very useful and important resources and always have been. However, because of the sheer number of applications received and reviewed, multiple review meetings are often scheduled for the same time, and it is often the case that one program director will have applications in their portfolio that are being reviewed at the same time in different meetings. It is therefore impossible to hear the discussion for every application. In addition, summary statements have recently been abbreviated, providing less information than they used to, and finally, the elimination of IC review and the drastic decrease in the ability of a program director to publish a funding announcement with specific review criteria all mean that program officers are less able to get the information that they need to make these informed decisions from review.
Finally, all of this is happening against a backdrop of a proposal to remove impact scores from the summary statement entirely (NOT-OD-26-088). Like other recent changes to NIH review, this proposal comes without consultation with review and program staff and without input from the external scientific community (the Center for Scientific Review Advisory Council was terminated in April 2025). In my opinion a “score” does not have to be numeric, and using bins that categorize applications as exceptional, highly meritorious, fair, needs work, or unfundable (or whatever other descriptors people like) could be just as useful in making funding decisions as numeric scores. This is what is done at the NSF and it works fine when it is implemented well. However, the idea that any numeric score would be generated and then not shared with the people who would find it most useful (i.e. the people making the funding decisions and the people who wrote the application and need to decide whether to revise and resubmit it) is ludicrous. The three categories proposed are “most competitive” (top 25%), “competitive” (26%-50%), or “not discussed” (bottom 50%). These categories are uninformative in the current climate where most ICs have a <10% funding rate, a problem created by the multi-year funding (MYF) policies instituted under this administration.
It is also happening against a backdrop where many more of the people making the funding decisions are political appointees selected for their connections to or alignment with the current administration and its political priorities. Other positions in the decision-making pipeline have recently been converted to political career appointments, making those staff members vulnerable to being fired if they go against the administration’s wishes. In the past, the transparency of impact scores, the details of the summary statement, the multiple discussions on funding plans both internally and with Advisory Councils, and the requirement for skip and reach memos were all mechanisms in place to ensure that funding decisions were not made arbitrarily or to favor or disfavor specific individuals or institutions based on preferences of those making the funding decisions. The current fear here, that I think we all need to pay attention to, is that these new policies are being put in place NOT to make it easier to advance the best science, but to make it easier to circumvent the processes and safeguards that have been in place to protect applicants from unfair and biased funding decisions. The result of all these changes in aggregate is that it will be easier for politicians to manipulate scientific funding decisions for political reasons without a reasonable recourse for applicants to challenge the outcome.