Can my NIH proposal include a Co-Investigator from another institution?

Collaboration and team science are encouraged in the current world of scientific research. Most biomedical advances are made not by an individual researcher working in a silo, but by a multidisciplinary team of scientists. Accordingly, you may be collaborating with investigators from within your institution. Adding them to your NIH proposal budget should be relatively seamless, even if they are in other departments or units. However, there is often confusion about how to budget investigators on a grant who work at different institutions.

Let's start with a quick review of NIH team role definitions. 

• A Program Director/Principal Investigator (PD/PI) is the individual designated by the applicant organization to have the appropriate level of authority and responsibility to direct the project or program to be supported by the award. 
• Multiple Principal Investigators (MPIs) who share responsibility to lead the project are allowed, but identification of a single Contact PI is required.
• A Consultant is an individual who provides professional advice or services for a fee, but normally not as an employee of the engaging party.
• A Co-Investigator is An individual involved with the PD/PI in the scientific development or execution of a project. The Co-Investigator may be employed by, or be affiliated with, the applicant/recipient organization or another organization participating in the project under a consortium agreement. A Co-Investigator typically devotes a specified percentage of time to the project and is considered senior/key personnel. 

In a previous post, I discussed the differences between a Consultant and a Co-Investigator. The primary distinction between them is that a Consultant provides only intellectual contributions to the project, while a Co-Investigator contributes their institutional resources, such as lab space and additional personnel. Including a collaborator as a Co-Investigator rather than a Consultant requires the establishment of a consortium agreement, which is a formalized agreement whereby a research project is carried out by the recipient and one or more other organizations that are separate legal entities. This is often referred to as a subcontract or subaward. Of note, adding a consortium agreement to your proposal will in most cases increase the amount you must budget for indirect costs (also called Facilities and Administrative costs or F&A) for both your institution and the subawardee institution. This may present budgetary constraints, particularly if you are planning a proposal for a funding opportunity that limits total costs rather than direct costs.

Sample Project Leadership Plans for Multiple PIs

Are you sharing the PI responsibility with another scientist?  Having 2 Principal Investigators can be a benefit to certain types of projects.  Given other responsibilities such as teaching and other research projects, it can also be helpful to have another person to share the workload.  NIH provides some examples of Multiple PI Project Leadership Plans here.  Why is this a necessary component of the application?  I believe it is in part because department heads and NIH personnel became frustrated with the messy divorces that can happen between PIs sharing equal responsibility for a project.  I have seen disagreements in approach, methods, and even interpretation of findings turn into all-out battles for control of projects.  Keep this in mind as you draft your leadership plan.  Be sure that one PI will have final say over certain types of matters and, if possible, designate an impartial third party or faculty committee to help make decisions when no agreement can be reached.  You will not regret it!

What is the NIH salary cap?

Beginning in 1990, each year Congress has set a limit on the amount of salary that can be paid to an individual on an NIH grant. The current fiscal year's notice (2011) states that no individual can be budgeted at a salary of more than $199,700 per year, prorated according to effort.

The salary cap is designed to prevent people from being "overpaid" on federal grants, at a level higher than most federal executives. This helps to ensure fairness and equality among individuals being paid by the government.

If you are budgeting someone on your NIH grant proposal with a salary of more than $199,700 per year, you will need to determine where the difference in salary will come from. In many cases, university departments will make arrangements to cover the difference in investigator salary and support from NIH. If you can't find written policies on this at your institution, talk to your Sponsored Research Office. If the grant is awarded, nobody wants to be scrambling after the fact to find the money to cover a salary difference!

WARNING: some individuals seem to think they can get around the salary cap by budgeting someone for more effort than they intend to actually spend on the project, essentially "overbilling" NIH to make up the difference. In most university environments, checks are in place to make sure that this does not happen. Why? This type of model would be defrauding the federal government. Not a good idea! If you need to save money on your grant, and at least one of your investigators is paid at an amount over the salary cap, you have a couple of options. 1) Budget the person at a small amount, and lessen their responsibilities on the project. 2) Hire the expensive person as a consultant, and work with him or her do determine a reasonable amount of payment for the duties needed. (NOTE: if the person who is paid over the salary cap is employed by the same institution as the PI, you may be prevented from budgeting him/her as a consultant by institutional rules.)

Consultant or Co-Investigator? How do I choose?

It can sometimes be difficult to determine whether an individual should be budgeted as a Consultant or Co-Investigator on a project. There are several factors to consider when making this decision.

1. Will this person be essential to carrying out the scientific duties of the project? Will he/she bear some responsibility for it's progress? Or will he/she simply be advising on one aspect of the project?
2. What type of time commitment is the individual willing to devote to the project?
3. Is the individual employed by another institution, or your own? If located at another institution, will your budget allow room for a subcontract, including any indirect costs?
4. If the person is located at your institution, will they be willing to devote measurable effort to the project? (NOTE: In most cases consultants are not able to be hired from one's own institution. Many universities, etc., do not allow this. In this case, if you want to budget someone from your own institution, he/she must be included in your personnel list, not budgeted as a consultant. )