The purpose of this post is to try to bring a teeny bit of clarity to the roiling landscape of biomedical research, healthcare, and public health in the U.S. This isn’t about outrage or blame or anything like that. I’m just hoping to highlight some things that I think are important to know about in the present moment, offer my thoughts on why they’re important to know about, and offer some ideas on what people and institutions do with the information. I’ll focus on things related to the NIH and the Dept of Health and Human Services, though if there are goings-on in other sectors that are likely to have a big impact on biomedical research and public health, I’ll go there.
SUPER DUPER IMPORTANT CAVEAT: Though I am a former federal employee and will look at things through that lens, I am not currently a federal employee. The golden rule is always this: TALK TO YOUR POINT OF CONTACT – your program officer, contracting official, whomever is appropriate. Talk to them early and as often as it takes. And if you’re not sure who that is, press pause right now and go do some digging. When appropriate here, I’ll offer thoughts on who the right POC might be for a specific thing. But there’s no substitute for up-to-date information coming straight from the people tasked with implementing policies, EOs, random tweets, whatever.
Okay, let’s do this.
We’re starting with a doozy – “Implementing a Unified NIH Funding Strategy to Guide Consistent and Clearer Award Decisions”. The announcement made on the NIH Extramural Nexus page on November 21, 2025 can be found here: https://grants.nih.gov/news-events/nih-extramural-nexus-news/2025/11/implementing-a-unified-nih-funding-strategy-to-guide-consistent-and-clearer-award-decisions
First, the timing. The changes to NIH’s funding strategy outlined in this post and the linked documents are set to go into effect starting with the January 2026 Council round. (Your grant’s assigned Council round can be found in a number of places, including on the summary statement.)
Second, here’s my high level overview of the changes from the above linked announcement.
None of the NIH’s Institutes/Centers/Offices (ICOs) will make funding decisions based on paylines going forward. Paylines are gone across the board, effective Jan 2026 Council round.
ICO funding policies, financial management plans, Funding and Operating Guidelines (FOG) pages, and similar information will all be centralized.
ICOs will use lots of other information in addition to overall impact scores to make funding decisions, with ICO Directors retaining delegated (potentially important word) decision-making authority over what gets funded.
Before moving on to some of the really important linked documents on the “Implementing” webpage, a few words about the above 3 bullets.
Here’s a very quick primer on paylines. For a long time, several of the NIH’s ICOs, including many of the really big ones, have used a payline process for making funding decisions about some types of grants. Usually, paylines were used to make funding decisions about research project grants like R01s and sometimes career development grants like K08s and K23s. When used, paylines were often set either based on the overall impact score or on a percentile ranking of the overall impact score. For example, an ICO might publish an intent to fund any K08 with an overall impact score of 28 or better. That same ICO might publish an intent to fund any R01 with a percentile score of 15%ile or better. Percentiles were typically calculated based upon a sliding 3 year window of overall impact scores, and the purpose was to normalize differences across different research areas, review groups, etc and to provide consistency.
You can easily see some advantages to the payline approach here. Though no funding decision is ever officially enacted until the Notice of Award is issued and funds available, intent to fund is a powerful statement on the part of an NIH ICO – “if you’ve scored X or better, you’re very likely to get funded”. Remember that overall impact scores and percentile scores are available long before the actual NoA is issued. A “fundable score” allows for critical planning activities that influence the success of the research to begin even before the NoA is issued. A “fundable score” is a powerful negotiating chip for an investigator and can be the difference between getting a job or not, getting promoted or tenured or not. Institutions can plan their finances much more intelligently and efficiently the sooner they know what grants are likely to be funded. Finally, paylines bring a certain kind of transparency. It doesn’t matter if the research is trendy, or if the ICO Director likes it or doesn’t like it, or whatever. “If you’ve scored X or better, you’re very likely to get funded.”
I’m not actually going to say much about the second bullet point above. I think centralizing the ICOs’ funding policies and financial management plans is actually a good idea and something that should’ve been considered a while ago. When I was a program officer, one of the most common pieces of advice I gave to investigators was to check their ICOs’ FOG (Funding and Operating Guidelines) pages, because they’re crazy useful and something I’d never even heard of until I worked at NIH. While I think ICOs need a fair bit of autonomy to determine funding policies and finance strategies that best meet the needs of the specific communities they serve, having the information all in one place is a positive step.
On to the third bullet. With paylines going away across the board, the question will be: How will investigators and institutions know what an overall impact score means? The extremes of the distribution will still hopefully be easy. An overall impact score of 50+ is difficult to justify funding even under the policies and practices of recent years past. An overall impact score of 10 (essentially a perfect score) ought to be fundable in pretty much any circumstance.
But, there are perhaps reasons to wonder now. The NIH has stated that many other factors will now be taken into account when making funding decisions. These other factors are summarized in what NIH is calling the Core Tenets. They include a variety of different pieces of information, from alignment with NIH mission to geographic distribution of NIH grants to “the total amount and type of NIH funding already available to each investigator”. (Note that the NIH has had a policy in place for a long time that outlines a Special Council Review process for investigators with $2M or more in total costs already allocated to supporting their research through active NIH grants - https://grants.nih.gov/grants/guide/notice-files/NOT-OD-22-049.html - and it is unclear whether or how the new framework will apply to investigators with less than $2M funding.) How all of these factors will be weighed, what will be apparent to investigators and institutions and what will not, how different ICOs will approach these new guidelines and processes… all of this and more remains to be seen. Policies are born of intent, and they live and die in the implementation.
Before we take a quick look at the actual policy statement itself that underlies the “Implementing” webpage, I want to come back to that word “delegated” I mentioned above. It has always been the case that ICO Directors have the delegated authority to make funding decisions. This isn’t an actual change. But, it has a potentially different implication under the new unified NIH funding framework. For instance, if someone above an ICO Director in the NIH/DHHS org chart decides that the ICO Director’s funding decisions don’t sufficiently “align with the NIH’s mission” (defined by whom?), that delegated authority could be reclaimed.
This is a decent segue to the “Achieving NIH’s Mission: Leveraging Funding Policies” document, linked at the “Implementing” website and found here: https://grants.nih.gov/sites/default/files/Leveraging-Funding-Policies-Framework.pdf
The policy reflects a lot of what is on the “Implementing” page, though a couple of additional points stand out to me, and they both read like instructions to the ICOs themselves rather than to the extramural community.
“ICOs should also carefully consider the budget to award for each grant, considering the actual need, opportunity costs, and good stewardship of taxpayer investments, rather than relying solely on the requested budget as evaluated by peer reviewers, as peer review is just one input in setting award budgets.”
“The success of an ICO, an ICD, and ICO staff will be assessed, in part, by the fulfillment of the core tenets of NIH’s unified funding policy approach. ICOs should consider how to appropriately document and communicate, to NIH leadership and the public, their decision-making to this effect.”
The first point seems to be expressing an expectation that ICOs should be really scrutinizing award budgets and awarding funds based on factors beyond peer review. Technically this could mean that ICOs have the authority to award budgets in excess of what is requested, but the implication seems to be that budgets are likely to get pinched and that perhaps ICOs could be assessed negatively if award budgets are not pinched.
The second point seems to suggest pretty clearly that ICO Directors and staff will be evaluated based on someone’s assessment of how well they’re upholding and documenting the implementation of the aforementioned core tenets. Uncertainty around what this means, how it will be implemented, how it will be documented, what the consequences are for perceived deficiencies, all of that and more will likely create a fair bit of anxiety.
So, what can you/we do?
1. Prepare for some increased turbulence in the next few months. Policy changes always come with some degree of perturbation as intent meets implementation (recall the Data Management and Sharing Policy, and that one was years in the making). Plan extra time wherever you can in any interactions with the NIH. Bring your patience and grace when dealing with NIH staff, recognizing that they’re doing their best amidst chaos as well and are potentially being faced with a whole new set of evaluation criteria.
2. Communicate early and often with everyone who makes NIH grants happen. This definitely means your program officer, and remember that old-fashioned phone calls are the best way to communicate complicated and nuanced information (also remember that cold calling is not the way to go… send an email saying “Can we schedule a call to discuss some questions we have?” and then schedule it). It also means your institution’s grants management team. It means your division chief and department chair. It might mean your institution’s office of general counsel. It means your students, postdocs, fellows, and lab teams.
3. Establish and nurture very open and honest communication and share information with your colleagues. This is more powerful than you think. When investigators all know who got what scores, who got funded and who didn’t, etc because they’ve all shared that information with one another, it makes for a very different kind of call with the NIH to discuss your own scores and funding decisions. Take it from someone who’s been on the NIH end of some of those calls! More importantly, we’re all going to be learning how the new unified funding framework will be implemented. No one will be able to have any sort of insight based solely on their own grants and those of their immediate collaborators. But if there’s widespread collaboration and info sharing about grants and their outcomes, it’ll be easier. There is definitely strength in unity here. The challenge is that we’re not used to doing this. Be creative. Be brave.
4. Make use of all the information available. Tune into ICO Advisory Council meetings for the public sessions. Read policy announcements carefully, maybe even incorporating summaries into regular information sharing venues like lab meetings, departmental seminars, etc. Don’t expect consistency across announcements. Rather, note the inconsistencies and follow up with NIH staff for clarification. See what other colleagues are saying on social media (being mindful of the provenance of information… trust but verify, including this post).
5. Communicate outward and upward. If you’re sufficiently protected professionally, let journalists know how the new funding framework is impacting your lab, your institution, and your state. Let your elected officials at the local, state, and federal levels know, and have the data ready to support your statements. If you’re early in your career, let your mentors and supervisors know how the new funding framework is affecting your decision-making about your career and the careers of your peers around the country.
Please comment below. If there are specific notices, policies, etc you’d like me to address in the future, let me know and I’ll do my best. We get through this together.
Further Reading:
https://grants.nih.gov/grants-process/award/funding-decisions
https://grants.nih.gov/sites/default/files/Leveraging-Funding-Policies-Framework.pdf