My Response to Proposed Changes to Reporting Outcomes from NIH Peer Review

October 13, 2026

I’m submitting this comment in response to NOT-OD-26-088: Request for Information (RFI) on Proposed Changes to Reporting Outcomes from NIH Peer Review. I thank the NIH for the opportunity to respond to the request for information.

The National Institutes of Health must maximize transparency in its reporting of peer review outcomes rather than obscure them with this ill-advised policy proposal. The proposal to withhold numeric scores in favor of broad categories reduces the overall usefulness of the peer review process for both awarded and unawarded grant applicants. Here, not only do I argue that NIH should not move forward with this proposed change to obfuscate quantitative scores, it should instead do much more to improve public accessibility to this information for the purposes of evidence building. Withholding exact scores harms researchers and their institutions. A broad “Competitive” designation spanning the 26th through 50th percentile does not distinguish an application that narrowly missed funding from one requiring fundamental redesign. Early career researchers may rely on the scoring to determine whether to resubmit, restructure, or redirect their work. Institutions also rely on this information for internal decisionmaking regarding bridge funding, startup extensions, and protected time. Furthermore, removing numerical scores from program officers will increase their workload and reduce consistency in funding decisions. Program staff currently rely on calibrated rank ordering. Without it, they may be forced to construct undocumented, ad hoc shadow rankings derived from written critiques. Retaining the final overall impact score and percentile ensures program officers can maintain consistent and documented funding decisions. Not only should this current plan be rejected, NIH should actually go in the complete other direction and provide more transparency. As Stuart Buck and I argued in Issues in Science and Technology last year, NIH (and other federal funders) should disclose full scores to grant applicants and the public for all *awarded *and *unawarded *applications. Understanding federal research and development investments requires knowing about both the awarded applications and the unawarded applications. Disclosing data on unfunded applications empowers the research community to evaluate whether agencies are supporting a wide range of ideas or favoring narrow theories. Providing this complete picture helps researchers refine their approaches, avoid duplicating unpromising projects, and discover potential collaborations much earlier.

To capitalize on this transparency, the NIH should work with OMB and GSA to implement a centralized marketplace for highly rated but unfunded grant applications, as recommended by Sandeep Patel, Stuart Buck, Ian Banks, and Amit Gupta here. This system would allow other federal agencies and philanthropic organizations to discover and fund thoroughly vetted research proposals. Transforming unfunded applications into an accessible market for scientific ideas will maximize the return on the existing peer review system and accelerate biomedical innovation. This approach aligns precisely with the principles of Gold Standard Science and the most recent OMB/OSTP joint R&D priorities memo (M-26-16). The M-26-16 guidance calls for rigorously studying, evaluating, and improving how Federal science is funded. Releasing comprehensive data on peer review outcomes provides the exact metascience capabilities required to achieve this objective, allowing agencies to identify research trends and understand the derivative impacts of their funding. Finally, the HHS Scientific Integrity Policy mandates that scientific processes remain free from interference or inappropriate influence that undermines impartiality or professional judgment. Providing public accessibility to the scores and outcomes of NIH peer review provides a record that allows Congress, advisory councils, and the public to evaluate the stewardship of taxpayer resources. Fully disclosing peer review scores protects the grant process from undue political interference and ensures funding decisions are demonstrably driven by scientific merit. I urge the NIH to reject the proposed categorization scheme, retain the reporting of the final overall impact score and percentile to applicants and program staff, and adopt a framework of complete public disclosure for all peer review outcomes.

References

1. Executive Office of the President. (2025). Executive Order 14303—Restoring Gold Standard Science. https://www.govinfo.gov/app/details/DCPD-202500636
2. Marcum, C. S., & Buck, S. (2025). Let unfunded grant applications see the light of day. Issues in Science and Technology. https://doi.org/10.58875/OVJU4078
3. National Institutes of Health. (2026). Request for Information (RFI) on proposed changes to reporting outcomes from NIH peer review (NOT-OD-26-088). U.S. Department of Health and Human Services. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-26-088.html
4. Office of Management and Budget, & Office of Science and Technology Policy. (2026). Ushering in a new golden age of American innovation: Fiscal year 2028 Administration research and development budget priorities (Memorandum M-26-16). Executive Office of the President. https://www.whitehouse.gov/wp-content/uploads/2026/07/M-26-16-Ushering-in-a-New-Golden-Age-of-American-Innovation-Fiscal-Year-2028-Administration-Research-and-Development-Budget-Priorities.pdf
5. Patel, S., Buck, S., Banks, I., & Gupta, A. (2026). America Already Built the World’s Largest Science-Vetting Machine. Macroscience. https://www.macroscience.org/p/america-already-built-the-worlds
6. U.S. Department of Health and Human Services. (2024). HHS scientific integrity policy. https://www.hhs.gov/sites/default/files/hhs-scientific-integrity-policy.pdf

Tags: general open science