As shared in our July 21 listserv (NIH Announces Policy Changes), NIH has issued Notice NOT-OD-25-132, which introduces a new policy limiting the number of applications a Principal Investigator (PI) or Project Director (PD) can submit per calendar year. This change is effective for applications submitted on or after September 25, 2025.
Key Policy Details
- Each PI/PD is limited to six applications per calendar year.
- This includes new, renewal, resubmission, and revision applications.
- Applies to all activity codes except T codes and R13 Conference Grants.
Since the listserv was sent out, NIH has released a set of FAQs related to this notice. Below is guidance based on those clarifications and common questions received by ORA.
Clarifications Based on NIH FAQs
Timing of Application Count
- Applications submitted for receipt dates between September 25, 2025 – December 2025 will be counted toward the 2026 calendar year limit, not 2025.
- NIH determines the count based on the calendar year of the Advisory Council review date, which for these submissions will be January 2026.
When an Application is Counted
An application is counted only after passing administrative review and proceeding to peer review.
- If rejected during administrative review (e.g., missing foreign justification, incorrect IC selection), it does not
- If rejected after peer review, it does count toward the PI/PD’s limit.
Who is Counted as a PI/PD
Applications are counted if the investigator is listed as either:
- PI/PD
- MPI (Multiple PI)
When identifying what counts toward the NIH application limit, it’s important to remember that NIH includes proposals for both Principal Investigators (PIs) and Multiple Principal Investigators (MPIs). At IU, MPI status is currently indicated on the KCPDD only when IU is submitting directly to NIH. If IU is a subawardee, the MPI status is not flagged in the KC Grants system. For a complete picture of an investigator’s NIH PI/MPI status, the best resource is NIH RePORTER, which provides the most reliable and comprehensive view of how an investigator is listed across NIH submissions.
Please contact ORA@iu.edu with any questions.