- I’m extremely busy this semester and don’t see how I can finish all my critiques in time. What’s the harm in asking my senior postdoc to help me out?
- The rules say that I can’t share applications with someone who has not been officially designated to participate in the peer review meeting. How do I know who has been officially designated?
- Which relationships constitute a conflict of interest in initial peer review?
- Which relationships do NOT constitute a conflict?
- Are training faculty listed on a training grant application considered to have Major Professional Roles?
- When is a collaborator or consultant considered to have a Major Professional Role in a project or application?
- What would NIH do to me if they thought I had broken confidentiality in peer review?
- How would NIH know about breaches of confidentiality in peer review?
In order to share the applications and meeting materials with anyone who is not on the panel, you must contact the Scientific Review Officer and ask permission to do so. Your postdoc would need to sign a confidentiality certification, conflict of interest certifications, and be added to the meeting roster.
Applications, proposals, and confidential meeting materials cannot be shared with anyone who is not a member of the study section where those documents and information are being reviewed. Officially-designated members include appointed members, temporary or ad hoc members, the Scientific Review Officer, and NIH staff with a need to know.
Generally speaking, conflicts of interest in initial peer review or technical evaluation result from one or more of the following scenarios:
- The potential for financial benefit
- Major Professional Roles in the work proposed
- Professional associations with individuals listed with Major Professional Roles in the work proposed
Membership on a Standing Study Section or Recurring Special Emphasis Panel
- Provision of resources or services that are freely available to the entire scientific community
- Co-authorship of a review article, position paper, professional group or conference report
- Data donations to a central repository or consortium
Institutional membership in a multicenter network unrelated to the application under review
For training grant applications, the Principal Investigator(s) or Program Director(s), and members of a curriculum committee or Advisory Committee, and any other personnel who will be involved in administration of the award or training program have Major Professional Roles. Therefore, they cannot serve on the review panel. However, faculty who could potentially gain a student or fellow supported in their laboratories on the training award have Professional Relationships, and therefore can serve on the panel but cannot review the application in question.
An individual with a Major Professional Role contributes to the scientific development or execution of the project in a substantive, measurable way, whether or not compensation is requested. In addition, the fact that an individual is named in an application can create a COI.
If NIH determines that you committed a bona fide breach of confidentiality in the peer review process, we could contact you and your institution, and ask you to step down from an appointed term of service on a study section. Depending on the severity of the breach, the NIH may refer the matter to the NIH Office of Management Assessment and possibly to the Office of the Inspector General in the Department of Health and Human Services, which could result in further administrative actions such as debarment or even criminal penalties. If the matter is referred to these authorities, the NIH would be unlikely to contact you or your institution first, as it now involves possible criminal violations.
Information about possible breaches of confidentiality come to the NIH in numerous ways. Often, an applicant will report that data, figures or text from his or her grant application appears in a publication authored by a reviewer on the panel where the application was reviewed. In addition to being a breach of confidentiality, this may also constitute research misconduct in the form of plagiarism.
We sometimes learn about breaches of confidentiality from other reviewers, colleagues and students of reviewers, or even members of the media. We also have internal controls to monitor access to our computer systems.