TLDR: The US National Institutes of Health (NIH) has introduced a new policy to address the overwhelming influx of grant applications, some of which are suspected to be substantially generated by artificial intelligence. Effective September 25, 2025, the NIH will cap the number of applications a Principal Investigator can submit to six per calendar year and will not consider applications substantially developed by AI as original ideas. This move aims to maintain fairness and originality in the review process and mitigate strain on the system.
The US National Institutes of Health (NIH) has announced a significant policy change to manage the increasing volume of grant applications, particularly those suspected of being heavily influenced or generated by artificial intelligence. The new guidance, detailed in Notice NOT-OD-25-132, titled ‘Supporting Fairness and Originality in NIH Research Applications,’ was released on July 17, 2025, and will take effect for applications submitted on or after September 25, 2025.
The NIH’s decision stems from observations of Principal Investigators (PIs) submitting an unusually high number of applications. While the percentage of PIs submitting more than six applications annually is relatively low, the agency has noted instances where AI tools have enabled some PIs to submit over 40 distinct applications in a single submission round. This rapid influx of submissions is deemed to ‘unfairly strain NIH’s application review process’ and raises concerns about the originality of the proposed research.
Under the new policy, the NIH will cap the number of ‘new, renewal, resubmission or revision applications’ a Principal Investigator can submit to six per calendar year. Furthermore, the NIH explicitly states that it ‘will not consider applications that are either substantially developed by AI, or contain sections substantially developed by AI, to be original ideas of applicants.’ This underscores the agency’s commitment to ensuring that all funded research proposals represent genuine, original thought from the applicants.
The NIH plans to continue employing ‘the latest technology’ to detect AI-generated content within applications. Researchers are cautioned that using AI tools, while potentially helpful for limited aspects of application preparation, carries risks such as plagiarism, fabricated citations, or other forms of research misconduct. Applications found to be substantially AI-generated may be referred to the Office of Research Integrity for investigation, potentially leading to penalties for researchers and their institutions, including grant termination.
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This policy aims to promote fairness and originality within the NIH’s research application system and to ensure the appropriate stewardship of taxpayer dollars by maintaining a high-quality grant application review process. The NIH had previously cautioned against AI use in the grant application process (NOT-OD-23-149) and disallowed its use in the reviewer process, but this new notice provides clearer expectations and stricter limitations.
