Agency Recognition of Multiple Principal Investigators on Federally Funded Research Projects, 54257-54260 [07-4638]

Agencies

• Office of Science and Technology Policy
• Science and Technology Policy Office

[Federal Register Volume 72, Number 184 (Monday, September 24, 2007)]
[Notices]
[Pages 54257-54260]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 07-4638]


=======================================================================
-----------------------------------------------------------------------

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.

-----------------------------------------------------------------------

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 https://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