Looking all the way ahead to FY16 …

Even though the upcoming Aug-Dec NIH deadlines will likely experience a higher number of applications due to the recent change in policy allowing unlimited resubmission of unfunded applications, you may want to be part of this crowded field since it is the last chance (aside from select PARs and RFAs) to be considered for FY15 funding.

Why is this important?

You may recall that the Budget Control Act of 2011 imposed caps on defense and non-defense discretionary spending plus a formula for sequestering funds to prevent deficit spending from FY13-FY21 in exchange for raising the debt ceiling. These caps resulted in the need to sequester funds from the budget, starting with 8% in FY13.

At the last possible moment, the Taxpayer Relief Act of 2012 delayed the FY13 sequester by 2 months and lowered the FY14 cap further to offset this delay, but FY13 was a rough year.

Then in December, the Bipartisan Budget Act of 2013 raised the non-defense discretionary spending caps for FY14 (from $472B to $491.8B) and FY15 (from $483B to $492.4B). However, it also extended the duration over which discretionary spending caps would be imposed from FY21 through FY23.

Congress is now working (or not) on the FY15 budget, which probably will not be known until well after the Oct 1 start date (necessitating a continuing resolution), and most likely will not be known until well after the mid-term elections, but the FY15 cap will have room to provide slightly higher appropriation levels than in FY14.

Although neither the House nor the Senate has moved an HHS appropriation bill for FY15 out of Committee, the Senate Appropriations Subcommittee mark-up bill for Labor, Health & Human Services, and Education currently allocates $30.46B to the NIH (increase of $606M, though $100M of this goes to the BRAIN initiative). The Subcommittee notes that “This level is sufficient, when combined with the $1M increase appropriated in FY14, to fully replace the FY13 sequester cut to NIH”. Not that we should be excited about being back where we should have been 2 years ago.

However, unless Congress passes additional legislation to provide relief from sequestration, the caps and potential cuts set for FY16-23 will remain in place.

Right now, the non-defense discretionary spending cap is at ~$493M for FY16 (same as FY15), though the Ryan budget drops this down to $450M (to eliminate any cuts to defense discretionary spending). Departments are not required to apply across-the-board cuts to remain within this cap, but for the NIH to be spared, another agency would need to be cut more severely. Think of HHS as a professional sports team with a salary cap: to fully fund the NIH, another program in Labor, HHS, or Education would need to come off the roster.

We have no idea what will happen in FY16 right now, especially with the midterm elections coming up. The Office of Management & Budget is currently asking all federal agencies to reduce their FY16 discretionary budget requests by 2% from the FY15 allocation.

So, to hedge your bets, you might want to get an application submitted for consideration in FY15. Also, please lobby your Congressional delegation (& please vote if you are eligible to do so) to be sure the NIH feels the love when they start negotiating whose appropriation is cut by how much under whatever spending cap is in place.

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