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.

Role Confusion: How to tell the difference between Co-Investigators, Consultants, and others for an NIH proposal

Role confusion comes up often when planning NIH grant proposals.  There are several terms that are sometimes used interchangeably which actually represent different things.  Also, NIH terms differ from those of other funding agencies.  It is important to pay attention to the various role definitions and ensure you are using them correctly in your application.

For example, I have often heard Principal Investigators (PIs) refer to individuals from within their organizations as "Consultants".  At most universities, a Consultant is unable to be listed from within the organization.  Consultants are paid directly from the grant - the money is sent to them in their name - and thus it is typical to include individuals from within the organization as Co-Investigators (with measurable effort) or Other Significant Contributors (with no measurable effort). 

The term "Co-PI" is also used often to describe multiple PIs on a grant application.  However, NIH does not recognize the term "Co-PI"; rather, NIH uses the Multiple PI model and the PIs are referred to as Contact PI or MPI.

Confused yet?

Thankfully, there is a helpful page from NIAID that lists key roles and their definitions.  Keep this handy as you develop your Budget Justification and write about the research team in your Research Strategy.

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. )