[Federal Register: September 24, 2007 (Volume 72, Number 184)]
[Notices]
[Page 54257-54260]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr24se07-33]
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OFFICE OF SCIENCE AND TECHNOLOGY POLICY
Agency Recognition of Multiple Principal Investigators on
Federally Funded Research Projects
AGENCY: Executive Office of the President, Office of Science and
Technology Policy (OSTP) and Office of Management and Budget (OMB),
Office of Federal Financial Management.
ACTION: Notice of policy on recognition of multiple Principal
Investigators (PIs) on awards made under Federal research and research-
related programs.
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SUMMARY: Many areas of today's research require multi-disciplinary
teams in which the intellectual leadership of the project is shared
among two or more individuals. To facilitate this team approach through
recognition of the contributions of the team leadership members, OSTP
issued a memorandum to all Federal research agencies on January 4,
2005, requiring them to formally allow more than one PI on individual
research awards. The Federal agencies then sought input from the
research community--scientists, research administrators, and
organizations that represent components of the scientific community--on
how best to implement this policy. This input was sought via a Request
for Information published in the Federal Register on July 18, 2005 that
posed a series of questions around core elements that will comprise
each agency's implementation plan. The six core elements, to be posted
on the Research Business Models (RBM) Web Site, include: (1) Statement
of what constitutes a PI; (2) designation of contact PI; (3)
application instructions for listing more than one PI; (4) PIs at
different institutions; (5) access to award and review information; and
(6) identification of all PIs in public data systems. The Supplementary
Information section of this Notice provides background on the Research
Business Models (RBM) Subcommittee of the Committee on Science (COS),
the plan to recognize multiple PIs on Federal research projects, a
summary of the responses to the Request for Information, and the
government response to the comments submitted. The final policy on the
recognition of multiple PIs is contained in the Policy Section.
SUPPLEMENTARY INFORMATION:
I. Background on RBM
This project is an initiative of the Research Business Models (RBM)
Subcommittee of the Committee on Science (COS), a committee of the
National Science and Technology Council. The RBM Subcommittee's
objectives include:
Facilitating a coordinated effort across Federal agencies
to address policy implications arising from the changing nature of
scientific research, and
Examining the effects of these changes on business models
for the conduct of scientific research sponsored by the Federal
Government.
The Subcommittee used public comments, agency perspectives, and input
from a series of regional public meetings to identify priority areas in
which it would focus its initial efforts. In each priority area, the
Subcommittee is pursuing initiatives to promote, as appropriate, either
common policy, the streamlining of current procedures, or the
identification of agencies' and institutions' ``effective practices.''
As information about the initiatives becomes available, it is posted at
the Subcommittee's Internet site http://rbm.nih.gov.
II. Background on the Recognition of Multiple PIs on Federal Research
Projects
Many areas of research, in particular, translations of complex
discoveries into useful applications, require multi-disciplinary and
inter-disciplinary teams. Innovation and progress still spring from and
depend on creative individual investigators, but collaborative synergy
plays an increasingly important role in advancing science and
engineering.
Multi-disciplinary research teams can be organized in a variety of
ways. Research teams vary in terms of size, hierarchy, location of
participants, goals, and structure. Depending on the size and the
goals, the management structure of a team may include: A director and/
or multiple directors, assistant or associate directors, managers,
group leaders, team leaders, investigators, and others as needed.
Regardless of how a research team is organized, a pertinent and
important question is how to apportion credit fairly if multiple
individuals provide the intellectual leadership and direction of the
team effort.
Acting on the recommendation of the RBM Subcommittee, the COS
concluded that team research would be enhanced if all Federal agencies
allowed more than one PI on individual research awards. Some agencies
already do this, either formally or informally, but the COS action,
which led to a directive to all research agency heads by the Director,
OSTP, dated January 4, 2005, extends the practice to all research
agencies as a matter of policy.
Request for Information
A Request for Information soliciting input from the research
community on several core issues related to recognizing multiple PIs
was published in the Federal Register on July 18, 2005 to guide the
agencies as they developed their plans for implementing the policy on
recognizing multiple PIs.
Respondents: A total of sixty-three comments were received from
twenty-nine biomedical scientists, twenty-three universities (Office of
Sponsored Projects or Vice President for Research), nine professional
associations, one small business, and one unknown affiliation.
Core Elements of Agency Implementation Plans, RFI Questions, Comments
From Respondents, and Agency Responses to Comments
General: Overall opinions on the Multiple PI policy (if stated in
the comment) were overwhelmingly favorable: 45 in favor, 8 opposed.
Answers to the individual questions in the RFI were listed and
categorized only if the respondent addressed that issue specifically.
Many respondents did not reply to the questions individually or address
some of the issues at all. Numbers in parentheses indicate multiple
responses citing the same issue or suggestion.
1: Statement of What Constitutes a PI
Q 1: Will listing more than one individual as a PI present any
difficulties for you or your institution?
Comments:
Need explicit criteria, give examples of what is and is
not a PI. (7)
PI means and needs to be just one individual. (12)
[[Page 54258]]
Keep Co-PI or Co-I titles. (9)
Possible abuse--too many PIs. (6)
Maintain maximum institutional flexibility and autonomy in
designating PIs. (7)
Institutions will have to revise processes and databases.
(7)
Concerns about accountability. (3)
New investigators named as PI might lose status as new
investigator. (4)
May be administratively cumbersome. (2)
Increased administrative burden. (2)
Concern about decision-making; if no one is in charge,
nothing gets done. (2)
Harder to evaluate departments for grant ranking.
Should be reserved for large, complex projects, not R01-
type.
Should allow use for just two close collaborators on R01-
type.
Require minimum percent effort (e.g., 20%). (2)
Do not require minimum effort.
Agency Response: The Research Business Models Subcommittee Task
Group on Multiple PIs considered these comments. The task group viewed
most of these as concerned with the basic role and definition of what
it means to be a PI. The agencies have agreed on a common basic
definition that is suitable across all agencies and research
institutions. (See Policy Section of this Notice.) In their
implementation plans, agencies may elaborate on the criteria for PIs in
their respective areas of science, giving examples of what does and
does not qualify as a PI for particular kinds of projects, as well as
the specific nomenclature that will be employed in implementation of
the multiple PI concept, e.g., Project Coordinator, PI and Co-PIs, or
Coordinating PI.
Institutions have the option to name one or more than one PI for
each project. It is the prerogative and responsibility of the applicant
organization to designate PI(s) for projects.
All PIs will be named in the official award. There will be no
Federal-wide limit to the number of PIs per project; however, an agency
may impose a limitation as part of their implementation plan.
2: Designation of Contact PI
Q 2: Do you see any difficulties that would be created by
designation of one PI as the Contact PI? Are there institutional issues
that the agencies should consider?
Comments:
Contact PI may become the de facto chief PI. (6)
Favor since it is important that institution/project speak
with one voice. (3)
Most junior PI may be assigned this role and/or may feel
put upon. (4)
Must be able to enforce communication responsibilities.
(2)
Create Chief Operating/Admin Officer. (2)
Create Lead PI or Project Director for management and
regulatory compliance issues.
Agency or institution could set up e-mail group for all
PIs. (2)
Diffusion of accountability. (2)
Not practical if awards to more than one institution.
Should be able to switch over course of grant.
Agency Response: All comments addressed the need for a single point
of contact between the institution and the Federal agency on issues
concerning scientific and technical aspects of the project. There was
some concern that either the designated Contact PI would become the de
facto overall PI on the project or the most junior PI would be assigned
this as a largely clerical role. It is the prerogative of the applicant
organization to designate the single point of contact. The agencies
consider this ``Contact PI'' role to be primarily for communication
purposes on the scientific and related budgetary aspects of the project
(see Agency Implementation section below.)
3: Application Instructions for Listing More Than One PI
Q3: What issues should the agencies consider in developing their
instructions for applications naming more than one PI?
Comments:
Management plan a good idea, but only when needed by the
type of project. (15)
Need detailed description of each PI's role and why that
justifies PI status; give examples of contributions that do or do not
justify PI status. (15)
When is agency approval needed for budget reallocation.
(3)
Grants.gov form allows only one PI. (3)
Uniform criteria should be adopted across agencies;
definition in RFI is adequate. (2)
Limit of PIs.
Need guidelines for compliance, coordination, decision-
making, publication.
Agency Response: Each agency will specify how its standard
application procedures will be modified, if necessary, to reflect the
overall policy accommodating multiple PIs. This may include
instructions for describing, within the research plan, the specific
areas of responsibility for each PI and how the team will function. The
government-wide policy does not mandate a formal management or
leadership plan, but a specific agency funding opportunity or
solicitation may require it.
4: PIs at Different Institutions
Q 4: Recognizing that agencies differ in the structure of their
business arrangements with institutions, are there ways for the
agencies to recognize PIs for a team effort involving multiple
departments or institutions that would work well for your institution?
What issues should the agencies consider in deciding on the most
appropriate award structure?
Comments:
Each type of award structure (subawards, separate awards)
has its advantages in different situations; maintain range of award
structures as appropriate to each situation. (12)
Linked awards are a good idea, when appropriate. (5)
Linked awards may affect institution's FAR simplified
acquisition threshold.
Need to address distribution of indirect costs among
institutions/departments. (3)
Accountability issues between institutions. (3)
Institutions can handle these issues themselves.
Agency Response: Many respondents noted that each type of award
structure (e.g., subawards or separate awards) has advantages in
different situations. The agencies agree and will continue to use a
range of award mechanisms. Institutions will have great latitude in
proposing arrangements that will work best for the particular project
and institutions involved. Agencies may, for example, use linked awards
(separate awards to each research organization participating in a
project), but the government-wide policy does not mandate their use.
5: Access to Award and Review Information
Q 5: Do you favor granting access to award and review information
to all named PIs, not just the Contact PI? Do you anticipate any
difficulties in granting such access?
Comments:
Favor granting access to all (27); oppose (0).
Agency Response: Since there was no controversy on this issue, the
agencies will make review and award information available to all named
PIs, to the extent that they currently make such information available
to a single PI. Agency implementation plans will describe how and when
this information can be accessed.
[[Page 54259]]
6: Access to Public Data Systems
Q 6a: Do you anticipate significant benefits from listing more than
one PI in agency databases? Do you anticipate any difficulties with
such listings?
Comments:
Will guarantee appropriate credit for team PIs (all
comments cited this).
Should include Co-Investigators as well as PIs. (7)
Enable better tracking of funding by agencies and
institutions.
Will benefit junior investigators. (2)
NIH ranking tables would be more accurate. (2)
Harder to monitor duplicate funding. (2)
Allows identification of potential future collaborators.
Provides for multiple contacts per project; but not all
contacts appropriate.
Q 6b: Do you anticipate using agency data systems with PI
information, such that investment in alterations to such systems would
be worthwhile?
Comments:
Warrants investment (9); maybe (2); no (0).
Numerous comments that this would be the most important
single aspect of implementing the multiple PI policy.
Agency Response: The comments emphasized the benefit of giving
appropriate credit for shared leadership of a team project. There was
some encouragement for agencies to track the participation of
scientists at less than PI level as well, but the policy will not
require this. Agency data systems will eventually list all PIs on
multiple PI projects. Because changes to existing data systems to
accommodate this requirement may be extremely costly, there will be no
mandated date for achieving these changes. Agency implementation plans
will be required to address the issue of when their data systems may be
expected to reflect the new policy on listing all PIs. Agencies may
also consult with the Office of Management and Budget's Electronic
Government (E-gov) office regarding system changes that are part of
implementation plans.
Other Considerations
Q 7: Overall, do you think that the changes proposed for official
recognition of multiple PIs will benefit multi-disciplinary and inter-
disciplinary research?
Comments:
The public comments uniformly reinforced the importance of
official recognition of multiple PIs in facilitating multi-disciplinary
and inter-disciplinary research.
Agency Response: No response is necessary; the policy will be
implemented as described for the preceding core issues.
Q 8: What other suggestions do you have for facilitating the
recognition of multiple PIs?
Comments:
Apportion budgets among PIs (favor: 18, distributed evenly
across PI, university, association respondents; oppose: 2, one
university, one association).
Minimize additional administrative burden of financial and
programmatic management. (3)
Need designation of responsibility for ethical conduct,
human subjects, animal welfare. (2)
Other agencies do not provide tracking data as NIH and NSF
do. (2)
Need procedures for resolving disputes.
Should have definition of Co-Investigator.
Urge rapid and uniform implementation across agencies.
Provide institutions with ability to apportion
responsibility along with recognition.
Allow collaborating PIs to participate in other grant
mechanisms (e.g., cap on number of grants/PI).
Agency Response: Most of these issues have been addressed in the
previous responses to the core issues. Implementation plans to be
posted on the RBM Web site for the policy on multiple PIs will use a
common format to address each of the core issues. Agencies will have
the latitude to expand upon the basic requirements for each issue, as
appropriate for their research communities, and will address these
variances in supplemental material provided through links to their own
agency Web sites or through published information.
Apportionment of budgets to individual PIs is not a core
implementation feature. If it is done at all, it will be addressed in
agency-specific implementation plans.
Policy
All Federal research agencies will recognize multiple Principal
Investigators (PIs) on research projects (grants and contracts).
Proposing institutions may identify individuals as PIs in proposals
when those individuals share the major authority and responsibility for
leading and directing the project, intellectually and logistically.
This policy does not replace the use of a single Principal Investigator
when that is most appropriate for the project.
Statement of What Constitutes a Principal Investigator
A Principal Investigator is the individual(s) a research
organization designates as having an appropriate level of authority and
responsibility for the proper conduct of the research, including the
appropriate use of funds and administrative requirements such as the
submission of scientific progress reports to the agency. When an
organization designates more than one PI, it identifies them as
individuals who share the authority and responsibility for leading and
directing the research, intellectually and logistically. The sponsoring
agency does not infer any distinction in scientific stature among
multiple PIs.
Discussion
It should be emphasized that naming multiple PIs for a proposed
research project is solely at the discretion of the proposing
institution(s). This concept is similar to the widely accepted practice
of recognizing the contributions and responsibilities of business
partners. The government's recognition of more than one individual as
PI also is not intended to alter the working relationship between team
members as they collaboratively allocate resources within the team,
subject to any constraints of the awardee institution or the Federal
agency under the award terms and conditions, nor as they apportion
credit for research accomplishments. Compliance requirements will
continue to apply to individuals and institutions, as they do today,
regardless of the designation of multiple PIs.
The agencies recognize that teams frequently cut across
institutional and geographic boundaries and that team efforts therefore
often involve subcontracting or consortia arrangements between
different institutions. Based on the experience that some agencies
already have with research teams spanning multiple institutions, the
agencies are confident that recognition of personnel involved in multi-
institution research projects will not substantively alter these well
established relationships between institutions.
Agency Implementation
In order to implement the policy on recognition of multiple PIs,
each Federal research agency will post in the Research Business Models
Toolkit its own plan for implementing the policy beginning in calendar
year 2008. Because changes to existing data systems to accommodate the
policy may
[[Page 54260]]
be costly, there will be no mandated date for achieving these changes.
Agency implementation plans will be required to address the issue of
when their data systems may be expected to reflect the new policy.
Agency implementation plans will be posted in the RBM website no later
than February 2008. Each agency's implementation plan will include the
following elements:
(1) Statement of What Constitutes a Principal Investigator
Each agency will describe if its definition of PI differs in any
way from the Federal-wide definition either routinely or in special
solicitations.
(2) Designation of Contact PI or Project Coordinator
Each project with multiple PIs will have a Contact PI, or Project
Coordinator, to whom agency program officials will direct all
communications related to scientific, technical, and budgetary aspects
of the project. By recognizing a person as a Contact PI or Project
Coordinator, a Federal agency will not confer any difference in
scientific stature to that person. Some agencies may designate a
specific term for this role in their agency-specific implementation
procedures, which may differ by solicitation or type of award
mechanism, for example Project Coordinator, PI and Co-PIs, or
Coordinating PI.
(3) Application Instructions
Each agency will specify how its standard application procedures
will be modified, if necessary, to reflect the overall policy
accommodating multiple PIs.
(4) PIs at Different Institutions
Agencies will use the full range of award mechanisms currently used
by each agency, and institutions will have great latitude in proposing
arrangements that will work best for the particular project and
institutions involved.
(5) Access to Review and Award Information
Agencies will make review and award information available to all
named PIs, to the extent that they provide this information to single
PIs.
(6) Identification of All PIs in Public Data Systems
Agency data systems will eventually list all PIs on multiple PI
projects. Agency implementation plans will address the issue of when
their data systems may be expected to reflect the new policy on listing
all PIs.
Pamela J. Smith,
Budget Analyst, Budget and Administration Division.
[FR Doc. 07-4638 Filed 9-21-07; 8:45 am]
BILLING CODE 3170-W7-P