NIH Wants a List of the Paperwork That Wastes Your Time. Here's How to Write a Comment That Changes Something.

Almost every survey of federally funded scientists finds the same thing: a large share of the research week goes to work that isn't research. The Federal Demonstration Partnership's Faculty Workload Surveys, the longest-running measure, have put that share at roughly 42 to 44 percent of faculty research time across three rounds. Congress noticed, and Section 2034 of the 21st Century Cures Act (2016) ordered NIH and its sister agencies to reduce administrative burden on researchers. A decade later, faculty still describe the problem in nearly the same terms.

NIH is asking again. On October 20, 2026, the agency's Extramural Nexus blog announced a Request for Information on "Opportunities to Reduce Administrative Burden in NIH Extramural Research" (NOT-OD-26-118). NIH accepts comments through an online form until December 8, 2026. Some early coverage, including some that cited the notice number NOT-OD-26-130, gave December 1 as the deadline. That address now leads to the same notice, and both the notice and the Nexus post say December 8. If you want no doubt at all, submit by December 1.

Most RFIs draw a pile of general complaints and get forgotten. This one is worth more effort than usual, for three reasons: the text is unusually specific, NIH has already acted on several reforms of the kind it's asking about, and the comment window overlaps a government-wide fight over federal grant rules that could pull the other way. This guide covers what the notice asks, what NIH can and can't change, and how to write a response that has a chance of turning into policy.

What the Notice Actually Asks

NIH says it wants to find requirements, policies, processes, forms, and systems "that impose unnecessary or uniquely disproportionate administrative burden on researchers and research institutions (e.g. small businesses, investigator career stage, institution type), without providing commensurate value to the stewardship, accountability, integrity, or effectiveness of NIH-supported research."

The notice lists seven areas for comment:

1. Requirements or processes that could be simplified, eliminated, consolidated, or moved to a later stage, at any point from application through post-award reporting, prior approvals, and certifications.
2. Duplication and inconsistency: places where the same information is requested more than once, or where requirements "vary unnecessarily across NIH."
3. Better use of technology and existing information, including reusing data already submitted, connecting systems so they talk to each other, relying on authoritative data sources, and the "appropriate use of artificial intelligence (AI), generative AI, or large language models" to summarize information NIH already has.
4. Requirements, guidance, or systems that create unnecessary complexity or uncertainty, especially those that fall hardest on early-stage investigators, smaller institutions, and organizations with thin grants-administration staff.
5. High-impact opportunities, meaning the changes that would help investigators, institutions, reviewers, or NIH staff the most.
6. Places where clearer guidance would prevent "overcompliance or assumed compliance that goes beyond stated requirements."
7. Reporting that collects information nobody uses: progress reports, recurring submissions, or certifications that "rarely inform decisions." NIH also invites ideas for "lighter-touch reporting paired with audit or independent verification."

Items 6 and 7 are the unusual ones. In item 6, NIH acknowledges that some of the burden researchers carry comes from institutions protecting themselves against requirements that don't actually exist. In item 7, NIH acknowledges that it collects reports it doesn't read. Federal agencies rarely put either point in writing, and a commenter who can document a specific case of either one is giving NIH exactly what it asked for.

The Reforms NIH Has Already Made

The background section lists recent changes, each with its own notice number. Together they show the kinds of reforms NIH is willing to make:

• Fewer funding opportunities and more reliance on broad, investigator-initiated announcements (NOT-OD-26-098)
• A simpler way to find opportunities and research areas of interest (NOT-OD-25-143)
• Application requirements and forms aligned with government-wide and other-agency standards (NOT-OD-26-094, NOT-OD-26-018)
• Removal of application requirements and procedural steps "that are no longer necessary" (NOT-OD-26-040)
• Some receipt dates moved onto NIH's standard receipt dates (NOT-OD-26-029)
• Less duplicative documentation (NOT-OD-26-019)
• Simpler documentation for research collaborations (NOT-OD-26-094)
• Fixes to requirements that caused "unintended administrative complexity" (NOT-OD-26-032, -063, -067, -100)

The pattern points to where a recommendation is most likely to land. NIH has been comfortable consolidating, aligning with other agencies, and deleting requirements. It also says it wants ideas for redesigning processes more fundamentally, which it describes as "collecting information once rather than multiple times; obtaining information later in the process when it is actually needed; relying on institutional certifications rather than submission of detailed information; using existing authoritative data sources... and adopting risk-based approaches in place of uniform requirements where appropriate."

That sentence is close to a template. A recommendation that matches one of those five moves (collect once, collect later, certify instead of document, use existing data, scale oversight to risk) fits a framework NIH has already approved.

What NIH Can't Fix Alone

The notice is open about its limits: "Some recommendations may be within NIH's authority to implement directly, while others may require coordination with the Department of Health and Human Services, the Office of Management and Budget, other Federal research agencies, or changes to regulation or statute."

This is important for writing a useful comment. Much of what researchers find most burdensome isn't NIH policy. The cost principles and audit requirements come from OMB's 2 CFR 200. Some research-security disclosure rules trace to NSPM-33 and statute. Human subjects and animal welfare rules have their own regulatory basis. A complaint about a statutory requirement will be logged and probably go no further.

The timing also makes the regulatory backdrop hard to ignore. OMB's proposed Uniform Grants Regulation, published May 29, 2026, would turn 2 CFR 200 from guidance into binding regulation and add steps, including review of discretionary awards by political appointees before issuance. The stopgap funding law blocks that rule, and any "substantially similar" one, through December 11. OMB Director Russ Vought has said the rule won't take effect before January 1. So while NIH is collecting ideas for removing steps, the government-wide rule could add new ones. A comment that measures what a proposed requirement would cost in staff hours or delay is useful in both settings.

Who Should Respond and What Each Can Add

Principal investigators know which documents get written, reformatted, and rewritten. Useful material from PIs includes how many hours a progress report takes compared with how often a program officer acts on it, how many times the same biosketch or other-support information is re-entered in different systems, and what prior-approval requests delay. Investigators early in their careers should point to steps that cost a new lab disproportionately more, since NIH names "investigator career stage" as a category it wants to hear about.

Research administrators and sponsored-programs offices hold the strongest evidence for item 6. If your institution requires something NIH doesn't, because guidance was ambiguous and the safe reading won, NIH wants to know. Saying "our office requires X because the Grants Policy Statement language at Y could be read to require it" points to a specific clarification NIH could issue.

Smaller institutions, minority-serving institutions, and small businesses have a specific opening. NIH lists "small businesses" and "institution type" as examples of disproportionate burden. A two-person grants office handling the same post-award reporting as a large university's 40-person office is the comparison NIH is asking for.

Peer reviewers are also invited. Reviewers can describe application sections they routinely skip or that don't affect their scores, which makes a case for cutting them.

Professional societies and associations can pool member data, and pooled data is the most persuasive kind. A society that surveys its members on hours spent on one form before December 8 will submit a stronger comment than a thousand individual complaints.

How to Write a Comment That Turns Into Policy

NIH says what it wants: "briefly identify the current requirement or process, describe the burden it creates, and suggest a practical alternative." Quantitative estimates of staff time "are welcome but are not required." Treat them as necessary anyway. A three-part structure works:

1. Name the exact requirement. Cite the form, field, Grants Policy Statement section, or notice number. A comment that says "progress reports are too long" can't be acted on. A comment that names a specific Research Performance Progress Report section and says what in it duplicates the prior year's submission can be.

2. Measure the burden. Estimate hours per occurrence, how many times per award or per year, and who does the work (PI, postdoc, administrator). Multiply it out. "Four hours per award per year across 600 active awards at our institution is 2,400 hours" makes the argument for you.

3. Propose the alternative and say what still protects accountability. NIH's framing is "burden reduction... while maintaining appropriate accountability." Each recommendation should say what oversight continues: an institutional certification, an audit sample, a check against an authoritative database. Recommendations that pair "lighter-touch reporting" with verification match the notice's own language.

Two practical cautions. First, the notice says responses "could be shared publicly in unredacted form." Leave out proprietary processes, unpublished data, personnel details, and anything about a specific award you wouldn't want made public. Second, one strong, specific comment is worth more than a full survey of grievances. You don't have to address all seven areas. Pick the two or three where you have evidence.

If your recommendation would need OMB or statutory action, say so, and identify the authority. NIH says it will sort recommendations by who can act on them. Doing that sorting yourself makes yours easier to move forward.

Where This Fits in NIH's Recent Comment Requests

This is one of several comment requests NIH has run in 2026. The agency's proposal to cap the number of Research Project Grants a single PI can hold drew about 3,300 responses, and NIH published a detailed "what we heard" summary, which suggests it reads and reports on these comments. A separate RFI from the Office of Laboratory Animal Welfare on annual reporting of live vertebrate animal counts (NOT-OD-27-001) closes December 21, 2026. That one is the opposite case: a possible new reporting requirement. Institutions with animal programs should answer both and connect them. The burden RFI is the right place to ask that any new count rely on data institutions already report to USDA or in their PHS Assurance documents, rather than adding a separate collection.

NIH's peer review process is still operating under emergency modifications adopted after the lapse in appropriations, and they remain in effect through the January 2027 Advisory Council round (NOT-OD-26-114). Comments that describe how review-side changes have affected applicant workload, such as resubmission timing or summary statements, are within scope as well.

The Bottom Line

Burden-reduction efforts have a mixed record. The National Academies' 2016 report on federal research regulation produced a long list of recommendations, and the share of faculty time going to administration barely changed. What separates this round is that NIH has shipped specific changes in 2026, named them by notice number, and asked for more of the same kind. That makes it more likely than usual that a well-documented recommendation becomes a notice in 2027.

The deadline is December 8, 2026, and submitting by December 1 removes any doubt. Name the requirement, measure what it costs, propose what replaces it, and say what still keeps oversight in place.