NIH just released NOT-OD-25-132: “Supporting Fairness and Originality in NIH Research Applications.”
There are two major changes that will shape how you plan and submit proposals beginning September 25, 2025:
- Originality & AI: NIH reiterates that applications must be the investigators’ original work and flags risks from AI-generated text (e.g., plagiarism, fabricated citations). Institutions should ensure appropriate use and verification.
- Submission limit: NIH will accept no more than six new, renewal, resubmission, or revision applications per PI (Principal Investigator) across the calendar year, whether listed as sole PI or Multiple-PI. Exemptions: T activity codes and R13.
What This Means for Your Proposal Process
- Pipeline discipline matters: As a best practice, your company will want a 12-month submission plan that ranks opportunities by value and readiness, so you don’t burn limited “slots.” This is especially important for teams with heavy PI collaboration.
- Stronger controls: Expect heightened scrutiny on text originality and references. A thorough review of your company’s proposal will help to ensure accuracy and limit uncertainty in the review process.
What To Do Now
- Map the year: List all planned submissions with PI roles and cap each investigator at six.
- Institute an AI-use protocol: Allow limited, non-substantive assistance (e.g., formatting), develop processes for verification of citations/originality, and keep internal notes if AI tools are used.
- Coordinate across collaborations: Assign an owner to track each investigator’s annual tally across all projects to protect against over submitting.
How EverGlade Consulting Can Help
The introduction of strict limits on AI use and a six-application cap per PI presents new risks for both large and small innovators competing for federal funding. Your next opportunity to secure support for a transformative project could arrive quickly and without the right planning, strategy, and preparation, you risk missing it. EverGlade Consulting helps you mitigate this risk by aligning your submission strategy with NIH’s new rules, implementing compliance protocols that protect against AI-related pitfalls, and putting in place tracking systems that prevent investigators from exceeding submission limits. With EverGlade’s guidance, your team can move with confidence, focusing energy on the most competitive proposals while staying fully compliant with NIH requirements. Key areas where EverGlade can make a difference include:
- Submission portfolio planning: We’ll work with you to develop a strategy that maximizes probability of award based upon your company’s current capabilities and future goals.
- Proposal development: From concept to submission, EverGlade can help you navigate this process. Our team is made up of experienced professionals that have successfully helped our clients win over $3 billion in non-diluted funding.
- Proposal tracking: EverGlade will help your team effectively manage and prioritize submissions to protect against exceeding the six submissions cap.
- Industry expertise: EverGlade has experience winning non-dilutive funding for a wide range of companies across multiple agencies. That breadth allows our clients to pursue, win, and manage their funding with confidence.
If your company has considered applying for federal funding, your federal funding journey starts here. EverGlade Consulting is a national firm that helps organizations win and manage federal awards. We offer services ranging from Pursuit, Proposal and Post-Award support to comply with federal regulations at agencies including BARDA, ARPA-H, NIH, DTRA, JPEO, DOD, DIU, DOE, and DARPA.
