I have received a lot of requests lately for help writing an NIH rebuttal, so it seems like a good time to talk about what they are and how to write one. Rebuttals seem to go in and out of vogue at NIH, and for whatever reason right now, many program officers (POs) are requesting them.
NOTE: This is not the same as the old “rebuttal and appeal” process that some of you NIH veterans might remember. That process was used when an applicant disagreed with the first level of review and was appealing it. See this ancient notice from 1996 if you are interested.
The so-called rebuttal document I discuss below is not a formal process, it is not described anywhere on the NIH website, nor does it occur as a standard part of an application review.
What is a rebuttal document?
After the first level of review at the study section, and before the second level of review at the council meeting, a program officer may ask an applicant to address the summary statement in a written document. The PO may call this written document a rebuttal, a response to the summary statement, or something similar – there isn’t an official name for this document. A PO might request it if you are close to the funding line – i.e., not well outside the funding range, nor a “slam dunk” for funding either. They typically ask for a 1–2-page document. There is no template, and the PO may or may not suggest topics to include in it.
Rebuttal document content
Ok, so if there are no instructions, what the heck does one include in this document? Well, let’s start by considering how the document will be used. You may not realize it, but your funding decision is not made at the study section meeting. Your study section awards a score, not funding – and contrary to popular belief, funding isn’t typically awarded at NIH by a strict cut-off in the score. The funding decision is made at the second level of review, which occurs at the triannual meeting of the Advisory Council to the institute director. Among the business discussed in the closed session of these meetings, program staff and council members will consider which applications to fund, focusing particularly on those applications that cluster around the funding line. Program staff may pitch certain projects for funding – indeed, during my time as an NIH staff writer, I saw some POs go to the mats to argue for funding for a particular project or applicant. This is where a rebuttal letter might come into play: A PO may use this written document to provide talking points for their funding pitch to council.
Based on my experience having seen POs make such pitches, I have come up with a simple template for the rebuttal document. Remember to format carefully so that it is easy for the PO to skim the page while presenting the information at the council meeting. Think very carefully about the information you want to highlight – this may be your last chance to make a pitch for funding.
Here is my template for a 1-2-page Rebuttal document:
REBUTTAL
Title: Use of Simpson Blue Dye in Tracking Cell Death in Dopamine Precursor Cells In Vitro
PIs: Homer Simpson PhD; Marge Simpson MD, PhD
Applicant Organization: University of Springfield
Review Group: DBBC
NOFO: PA-25-301
Application Number: 1R01ODXXXXXX-01
Project Summary: (one paragraph)
Key Strengths (bulleted list; Underscore ways the project addresses high-level funding priorities of the institute. If it’s a topic-specific NOFO, emphasize responsiveness to the NOFO.)
Response to Key Critiques (bulleted list that includes a brief response to some of the main criticisms the reviewers had with the project. Paraphrase the key critique preferably in a few words – you don’t want to waste valuable space re-stating the problem. Instead, save the space for your response. If the PO asked for a two-page doc, make the Response to Key Critiques page two; if the PO asked for a one-page doc, use the same headers but make the Summary, Key Strengths, and Response to Critiques shorter.)
