Request for Information on the Plan to Recognize Multiple Principal Investigators on NIH Grants

Notice Number: NOT-OD-05-055 (also see NOT-OD-06-036)

Key Dates
Release Date: July 29, 2005
Response Date: September 16, 2005

Issued by
National Institutes of Health, Office of the Director, Office of Extramural Research (http://grants.nih.gov/grants/)

The NIH is seeking input and advice from the scientific community on various concepts associated with permitting more than one Principal Investigator to be associated with an NIH funded grant, contract, or cooperative agreement. This Request for Information (RFI) is being issued at the same time as a companion RFI from the Office of Science and Technology Policy (OSTP), as described below. The RFI issued by the OSTP asks for input from the broader scientific community about the overall concept of permitting multiple PIs on applications and awards for federal research support. This RFI, issued by the NIH, asks for input on policies and issues of special interest to the health-related research community.

Background

Modern biomedical research increasingly requires multi-disciplinary or inter-disciplinary teams. Innovation and progress still depend on creative individual investigators, but increasingly, collaborative synergy is necessary to fully realize the promise of modern biomedical and biobehavioral research. The current incentive and reward structure for academic investigators, however, is strongly influenced by the policies of their academic institutions, their funding agencies, and the scientific journals in which they publish. The present system takes its structure from the paradigm of the single Principal Investigator (PI) working with a small group of subordinates on an independent research project. Although this model has worked well and encourages creativity and productivity, it may also discourage multidisciplinary efforts and collaboration. Increasingly, health-related r esearch involves teams that vary in terms of size, hierarchy, location of participants, goals, disciplines, and structure. There is growing consensus that team science would be encouraged if more than one PI could be recognized on individual awards. The NIH intends to adopt a multiple-PI model as recently directed by the OSTP. The multiple-PI model is intended to supplement, and not replace, the traditional single-PI model. Although the details of the multiple-PI policy remain to be worked out, the following describes a probable implementation strategy.

Tentative Implementation Plan

The NIH plans to adopt or create grant application forms that include sections for more than one PI. Each of the listed PIs will be designated by the grantee institution and will be expected to share responsibility for directing the project or activity supported by the grant. As with current policies, each PI will be responsible and accountable to the grantee institution and to the NIH for the proper conduct of the project or activity.

Information on the identity of each PI will be stored in NIH databases and will appear in reports including: CRISP (see http://crisp.cit.nih.gov/), Notices of Award (NoA), reports accessible through the NIH Commons (see https://commons.era.nih.gov/commons/), and summary statements. To facilitate communication with the NIH, the institution will be asked to select a contact PI at the time of application. The contact PI could be changed during the course of the award if requested by the research team/institution. The contact PI will be responsible for relaying communications between all of the PIs and the NIH; for example, he or she will keep other PIs notified of correspondence from the NIH and will coordinate submission of all reports back to the NIH. Being named contact PI will not confer any special authority or responsibility for the project. All PIs will be responsible and accountable for reporting as required by the terms and conditions of the award. As in current applications, peer reviewers will consider whether the designated PIs have appropriate training and experience to carry out the proposed study.

The NIH will ask for a Leadership Plan in applications involving more than one PI. This approach is currently used for cooperative agreements and various types of multi-project grants. The Leadership Plan will describe the roles and areas of responsibility of the named PIs. The Leadership Plan also will describe the process for making decisions on scientific direction, allocating resources, and resolving disputes that may arise. The purpose of the plan is to facilitate and enhance scientific productivity and to protect the project in the case of disagreements. Consistent with current NIH practice, the quality of the Leadership Plan will be considered by peer reviewers during the assessment of scientific and technical merit.

The NIH anticipates modification or adoption of grant application forms that permit the involvement of more than one PI before the end of FY 2006.

Information Requested

OSTP Request for Information: As mentioned in the introduction, the OSTP has issued a separate but contemporaneous RFI. The OSTP is asking for input from the scientific community on the overall concept of multiple PIs as it relates broadly to all federal research agencies. The OSTP RFI can be viewed at http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/2005/pdf/05-14015.pdf. Comments to the indicated questions in the OSTP RFI should be transmitted as directed in that document.

NIH Request for Information: This NIH RFI is asking for input on issues and policies that may be of special interest to the health-related research community. Principal Investigators, Faculty, Staff, Administrators, Professional Societies, Postdoctoral Fellows, Students and others who are or are likely to be engaged in or affiliated with NIH funded, health-related research supported by a grant, cooperative agreement, or a contract should feel free to comment on the issues raised. Comments and opinions related to the NIH RFI can be entered at a special website available at http://grants.nih.gov/cfdocs/mult_pi/add_mult_pi.htm. Responses to the RFI or any of individual elements of the RFI are optional. The NIH site will permit anonymous responses. Responders should be aware that the information provided will be analyzed and may appear in various reports. Additionally, the government cannot guarantee the confidentiality of the information provided.

The information requested covers the following issues:

  1. Allocation of funds to individual PIs;
  2. The impact of multiple-PI projects on NIH departmental ranking tables;
  3. The use of linked awards when PIs are located at different institutions.

Detailed Request for Comments:

1. Allocation of funds: Experience suggests that institutional recognition of faculty and staff for the purpose of promotion, tenure, and space allocation frequently includes an assessment of the ability to attract externally sponsored research awards and the financial impact of those awards. However, intellectual contributions to particular projects rarely track exactly with costs or expenditures related to projects or awards. For example, a mathematician may be integral to the design and conduct of a project, but the costs attributed to the mathematician may be small compared to other aspects of a project that involve tissue culture or clinical assessment. The NIH would like to structure team awards in a way that would enable all PIs on a project to receive proper credit from their institution.

In addition to the issue of credit, a second consideration involves fluidity of funds for the project. One possible strategy for managing funds in the case of an award with more than one PI would include a shared budget with joint oversight by the PIs throughout the project period. This would provide the flexibility needed to move funds between PIs and various aspects of the project as required. A second strategy would involve a joint decision at the time of application about how the funds should be divided in order to provide a working budget for each PI at the time of award. During the project period, funds could be re-allocated via a joint decision of the PIs. This approach could be considered analogous to the current process of reallocating funds between budget categories in awards with detailed budgets and could trigger the need for NIH approval if changes are substantial.

Both of these issues – distribution of credit for the award and fluidity of funding – would be influenced by whether or not institutions wish to allocate funds between the PIs and how such information would be reported and tracked by the NIH. Considering the potential impact of allocation on these important issues, please provide input on the following:

a) Should the NIH permit the PIs/grantee institution to ask for apportionment of the budget to each PI? y/n
b) Should the NIH report budget apportionment on the Notice of Award (NoA) and track changes in apportionment throughout the project period? y/n
c) Do you think that apportionment will interfere with or facilitate the efficient operation of a research team? interfere/facilitate

2. Departmental Ranking Tables: The NIH prepares tables that rank institutions and medical school departments by the amount of NIH funding they receive. Those tables can be found at http://grants1.nih.gov/grants/award/rank/medindp03.htm . When the NIH allows PIs from different departments to be identified on an individual research award, assignment of funds to specific departments will be difficult. There are a number of different approaches that the NIH could pursue with awards to multiple PIs. The approach ultimately chosen will be influenced by whether dollars are apportioned to individual PIs. In the absence of financial apportionment, the NIH could simply list all grants to a particular institution and allow the community to make budgetary assignments to specific departments.

The NIH is interested in determining whether these tables are useful to the scientific community. This information will inform any decision regarding the departmental ranking tables.

a) Does your institution use the departmental ranking tables? y/n
b) Would your institution be affected if the NIH eliminated the departmental ranking tables? y/n
c) If you answered β€œyes” to the previous question, please indicate how your institution would be affected by the elimination of the departmental ranking tables.
d) Would lists of awards with their associated PIs and their institutional and departmental affiliations satisfy your institution's need for information about NIH awards attributable to specific departments? y/n

3. Awards to More than One Institution: The NIH frequently makes awards that involve more than one institution. In almost all cases, however, there is a single awardee institution and a secondary institution that receives an allocation of funds from the primary award in the form of a subcontract or some other type of consortial arrangement. In most NIH reports, the entire award amount is assigned to the awardee institution.

Under the proposed multiple-PI model, projects led by PIs from different institutions would likely continue to use the subcontract approach. Making a single award would appear to preserve the concept that the research is being conducted as a single, integrated project. It may be possible, however, for the NIH to explore the concept of Linked Awards. Under a Linked Award option, the NIH would issue two or more awards for a project that involves collaboration across two or more institutions. This would have the advantage that each PI/institution would receive credit for the project and each PI would have financial authority over his/her part of the project. It might have the disadvantage of fostering leadership and financial boundaries within a collaborative project. The NIH, therefore, seeks your input on the value of Linked Awards in cases where there are PIs at different institutions.

a) Do you think a consortial or subcontract arrangement between the primary and secondary institution permits the leadership team to effectively manage a project spanning the involved institutions? y/n
b) Does a subcontract arrangement create inequities between PI(s) at the awardee institution and PI(s) at the subcontract institution(s)? y/n
c) Do you see value in offering Linked Awards in the case of multiple PIs located in different institutions? y/n
d) Do you think a Linked Award arrangement will interfere with or facilitate effective project management? Interfere/facilitate

Responses

All responses to the questions raised in this RFI will be recorded using a special website available at http://grants.nih.gov/cfdocs/mult_pi/add_mult_pi.htm. Responses will be accepted until September 16, 2005.

Inquiries

Please enter all comments on the special website located at http://grants.nih.gov/cfdocs/mult_pi/add_mult_pi.htm. Specific questions about this notice may be directed to Dr. Walter T. Schaffer, Senior Scientific Advisor for Extramural Research, Office of Extramural Research, National Institutes of Health. Dr. Schaffer can be reached by telephone at 301-402-2725 or by email at ws11q@nih.gov.

This request for information is for planning purposes only and shall not be construed as a solicitation for applications or as an obligation on the part of the government. The government will not pay for the preparation of any information submitted or for the government's use of that information.

Acknowledgement of receipt of responses will not be made, nor will respondents be notified of the government's assessment of the information received. No basis for claims against the government shall arise as a result of response to this request for information, or in the government's use of such information as either part of an NIH evaluation process or in developing any subsequent policy or announcement.


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