WOW. This comment from dsks absolutely nails it to the wall.
The NIH is supposed to be taking on a major component of the risk in scientific research by playing the role of investor; instead, it seems to operates more as a consumer, treating projects like products to be purchased only when complete and deemed sufficiently impactful. In addition to implicitly encouraging investigators to flout rules like that above, this shifts most of the risk onto the shoulders of investigator, who must use her existing funds to spin the roulette wheel and hope that the projects her lab is engaged in will be both successful and yield interesting answers. If she strikes it lucky, there’s a chances of recouping the cost from the NIH. However, if the project is unsuccessful, or successful but produces one of the many not-so-pizzazz-wow answers, the PI’s investment is lost, and at a potentially considerable cost to her career if she’s a new investigator.
Of course one might lessen the charge slightly by observing that it is really the University that is somehow investing in the exploratory work that may eventually become of interest to the buyer. Whether the University then shifts the risk onto the lowly PI is a huge concern, but not inevitable. They could continue to provide seed money, salary, etc to a professor who does not manage to write a funded grant application.
Nevertheless, this is absolutely the right way to look at the ever growing obligation for highly specific Preliminary Data to support any successful grant application. Also the way to look at a study section culture that is motivated in large part by perceived "riskiness" (which underlies a large part of the failure to reward untried investigators from unknown Universities compared with established PIs from coastal elite institutions).
NIH isn't investing in risky science. It is purchasing science once it looks like most of the real risk has been avoided.
I have never seen this so clearly, so thanks to dsks for expressing it.