NOT-OD-25-132 - AI, application limits and updated FAQs
Memo sent to RAC 8/28/25
Dear RAC,
Good morning. On July 17, 2025, the NIH released a significant policy update—NOT-OD-25-132: Supporting Fairness and Originality in NIH Research Applications —which introduces new guidance on the use of artificial intelligence (AI) in grant applications and imposes limits on the number of submissions per Principal Investigator (PI) annually, effective for applications submitted to the September 25, 2025 date and beyond.
NIH also published FAQs. Based on the FAQs and further info obtained by SPA, this email provides clarification on the application limitation aspect of the policy update, which states:
“NIH will only accept six new, renewal, resubmission, or revision applications from an individual Principal Investigator/Program Director or Multiple Principal Investigator for all council rounds in a calendar year. This policy applies to all activity codes except T activity codes and R13 Conference Grant Applications.”
A PI/PD’s application limit will be counted based on the calendar year of the Advisory Council date when the application is scheduled to be reviewed. The January 2026 Advisory Council in calendar year 2026 is the first to follow the new Policy and corresponds with scientific review dates in October to November 2025 (Cycle II).
Only applications where the investigator is listed as a PI/PD or MPI count toward the investigator’s yearly limit. NIH does not limit the number of applications NIH will accept when an investigator is listed under other roles (e.g., co-investigator, mentor, subaward PIs, or other key/ senior personnel). Such other roles, like Project PI (on a P01)/Core Director (or similar multicomponent grant like the Cancer Center P30), these roles are not discrete from other application designations (e.g., a project or core leader could be listed as an MPI or a co-investigator on an application – and that application would then be counted toward the limit).
Any of the following applications count towards a PI/PD’s or MPI’s limit of six applications: new, renewal, resubmission, or revision submissions. Administrative supplements, non-competing renewals, Type 4 applications, and Type 7 applications are not counted toward the maximum. The Policy applies to all activity codes except T activity codes, Loan Repayment Programs, X01 Applications that are not Council reviewed, R25s, and R13 Conference Grant Applications.
An application is counted towards the limit of six after passing administrative review prior to peer review. Applications that are withdrawn after peer review count toward the maximum. This email is not the entirety of the NIH policy update or NIH FAQs. We recommend reading them both closely.
Thank you and please reach out to SPA with any questions.
John B. Evermann
Executive Director
Sponsored Programs Administration