Introduction
On November 20, 2006, the NIH published a Grant Notice entitled, "Establishment of Multiple Principal Investigator Awards for the support of Team Science Projects." The following outlines key elements of that policy and UW guidance and processes that have been created to adapt to this new feature of NIH grant applications.
Key to the appropriate use of the Multiple PI mechanism is a careful analysis of the requirements of the NIH Principle Investigator definition and the development of a project leadership plan. The UW anticipates that this mechanism will be used appropriately and that the leadership plan will reflect an organization and mechanism for dispute resolution that reflects the requirements of the UW.
Pre-Award Process
Designating Multiple PIs
The designation of Multiple PIs should be based on the requirements of the research project. It is anticipated that the number of PIs will rarely exceed five (5). The UW also expects that the Contact PI on the NIH application will be the contact person within the UW and will act as the primary point of communication with the research team during the proposal and award processes.
The person designated as the PI on the "SF424 (R&R)" face page, Block 15, will be the Contact PI. This is the individual through whom NIH expects communication regarding the project to flow. Aside from this communication responsibility, there is no difference between the Contact PI and other PIs on a project. All share the same rights, responsibilities and credit. All PIs will have access to the ERA Commons information about the proposal, all will be listed on the NGA, and all will be identified in the CRISP system as PIs.
Once the Contact PI is entered into Block 15 of the face page, his/her information will populate the "PROFILE Project Director/Principal Investigator" block on the "Research & Related Senior/Key Person Profile (Expanded)" page. You will still need to enter this individual's ERA Commons username in the "Credential, e.g. agency login" field and upload his/her Biographical Sketch.
The remainder of the PIs will need to be entered into the "PROFILE Senior/Key Person X" (where X is a number from 1-40) block on the "Research & Related Senior/Key Person Profile (Expanded)" page. The Project Role for these individuals will be "PI/PD." (Note that NIH does not recognize "Co-PI" as a valid project role.) Also, be aware that the ERA Commons username for each individual listed as a PI/PD must be included.
Leadership Plan
A leadership plan is required for all Multi PI proposals.
Following are the instructions from the "NIH SF424 Application Guide" regarding the content of the plan:
For applications designating multiple PDs/PIs, a leadership plan must be included. A rationale for choosing a multiple PD/PI approach should be described. The governance and organizational structure of the leadership team and the research project should be described, including communication plans, process for making decisions on scientific direction, and procedures for resolving conflicts. The roles and administrative, technical, and scientific responsibilities for the project or program should be delineated for the PDs/PIs and other collaborators.
If budget allocation is planned, the distribution of resources to specific components of the project or the individual PDs/PIs should be delineated in the Leadership Plan. In the event of an award, the requested allocations may be reflected in a footnote on the Notice of Grant Award.
The UW requires that all leadership plans, at minimum address three points:
- The Contact PI will assume the same functions within the UW as with NIH and will be the person responsible for communication with the other project team members and OSP during proposal submission and throughout the project period.
- Any dispute arising from the project will be addressed first by the PIs. If a resolution cannot be obtained, then the respective Chairs and/or Deans will convene to resolve the dispute. Should further resolution be necessary, the dispute will be referred to the Vice Provost for Research by the respective Deans, and the decision of the Vice Provost will be final.
- The PIs will follow the intellectual property policies and practices of their respective institutions, with support and assistance from the applicable technology transfer office(s).
The leadership plan will be uploaded as a separate (PDF) file to Block 14 of the "PHS 398 Research Plan" form page.
Required Certifications
NIH requires the UW to maintain on file the following certification for all PIs designated on a project:
"I certify that the statements in this eGC1 and the related sponsor application are true, complete and accurate to the best of my knowledge. I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties. I agree to accept responsibility for the scientific conduct of the project and to provide the required progress reports if a grant is awarded as a result of this application."
These certifications are obtained through SAGE as described below.
Multiple PIs and the eGC-1 (SAGE)
OSP and ORIS, as well as other UW offices, are still working on revising our systems and business processes to accommodate the new Multiple PI policies. In the meantime, taking the following steps will ensure that Multiple PI applications are processed correctly and the UW remains compliant with NIH rules.
Designating Multiple PIs
The GC-1 has two pages where personnel are entered: the "PI & Contacts" page and the "Personnel" page.
The Contact PI should be entered on the "PI & Contacts" page. This will ensure that communication between the UW and the sponsor carries the Contact PI's name, facilitating smooth processing of the application and any supplemental documentation.
The remainder of the Multiple PIs should be entered on the "Personnel" page. "Multiple PI" has been added to the list of "Role Types" on the "Personnel" page, so each of the individuals serving as PI should be named and given the role of "Multiple PI."
Certifying
The Contact PI will be the only PI who is required by the system to approve the GC-1. When he/she does so, the system will require the individual to attest to the above noted NIH-required certifications. The certification from the Contact PI is thus stored in the SAGE system.
It is anticipated that the approval engine in SAGE will eventually be modified to require approval from all of the Multiple PIs. Until that happens, however, there are two mechanisms for obtaining the NIH-required certifications from these individuals:
Option 1: Each of the non-contact Multiple PIs is added as an Ad Hoc approver to the GC-1. This will require those individuals to approve the GC-1. However, in order to confirm the necessary certification, the Multiple PI will need to paste the text of the certification into the "Comment" field associated with approving. The necessary text is in the help menu associated with the "Approval" page, from where it can be cut and pasted.
Option 2: Also in SAGE is a link to a PDF file of the required certification. The Multiple PI may print this file, print his/her name on the page, sign the document, scan it, and then upload it to the GC-1 as an attachment.
OSP's review of applications designating multiple PIs will include confirming that the necessary certifications have been received from all of the PIs.
Subcontracts
The NIH is working on a linked award mechanism for situations where the named PIs are not at the same institution. Until NIH develops the linked award mechanism, the subcontract process will be used to provide funding to those PIs not affiliated with the UW. Subcontracts to other participating PIs at other institutions will be linked to the parent budget. Other subcontracts applicable to an individual PI's portion of the project and not to a named PI on the award will be linked to the sub-budget for that PI.
Post-Award Process
Parent Sub-Budget
The parent sub-budget mechanism will be used to establish individual budgets for each UW-affiliated PI. The budget for the initial Contact PI will be designated the parent budget and will retain that attribute throughout the life of the competing cycle. OSP will notify GCA if there is a change in the Contact PI. A change in the Contact PI will not change the parent/sub-budget roles within the financial system of the university.
The parent sub-budget mechanism for multi-PI awards will be identified through the use of a grant control flag so that they can be identified separate from other parent-sub relationships.
The Office of Sponsored Projects (OSP) will issue one Notice to Establish Account (NEA) per agreement to Grant and Contract Accounting (GCA). The NEA will identify all applicable sub-budgets and the allocations for all budgets. If the NGA does not identify amounts for the sub-budgets, a TRANSPASU will be used to establish sub-budgets as appropriate.
A single copy of the NEA will be sent to the Contact PIs department when the budget is established. GCA will notify all PIs and departments via email of the establishment of the budgets.
Rebudgeting
Regardless of an allocation plan, the institution has authority to rebudget within a particular allocation or across allocations via a joint decision of the PIs without prior approval of NIH.
Requests to rebudget an individual budget may be initiated by the PI associated with that budget. Requests to rebudget between sub-budgets will be signed by all PIs whose budgets are affected and processed through the Contact PI for submission to GCA.
Deficits and unallowable costs
Each named PI is financially responsible for their budget per GIM 2 - "Fiscal Responsibilities on Grant and Contract Accounts." The PI is to ensure that all expenditures are reasonable, allocable and allowable per the terms of the agreement and that expenditures do not exceed the available funds for the individual budget. If a deficit or disallowance occurs under a grant or contract account, the named PI on the budget, in consultation with his/her chair or dean, is to advise the Grant and Contract Accounting Office as to the appropriate disposition. Reliance on available funds in an associated sub-budget is not justification for exceeding the available funds in an individual budget.
Changes in level of effort
Changes in committed effort of 25% or more, or absence from leadership of the project for 3 months or more for any named PI requires prior sponsor approval. Requests for approval would be processed according to the leadership plan and sent to OSP through the Contact PI. (See GIM 35 - "Effort Reporting Policy for Sponsored Agreements" - for a discussion of faculty effort.)
Cost sharing
Cost sharing will be associated with the budget for the PI that commits the cost share. OSP will identify the individual budgets that have associated cost share. The responsible department will provide the GC1 Addendum to OSP for the budget(s).
Closing
The procedures for closing a budget associated with a multi-PI award will follow the same process as is currently done for individual budgets with the following exceptions:
- Notice of Expiring Budget (NOE) letters and the parent-sub detail spreadsheet will be sent to each department.
- Unexpended balances and deficits will not roll up to the parent budget. Each PI is responsible for the timely closeout of their individual budget.
- If cost share has been committed, it will be tracked in relation to the PI that made the commitment.
- Program income budgets will be linked to the parent budget and closed in association with the individual budget to which it is related.
Additional Information and Contacts
When applicable, this form must be completed and submitted to OSP at the time the application is reviewed. Cost sharing occurs when an application commits allowable expenses (i.e., personnel, tuition, equipment or services) for which the research grant will not be charged.
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