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The American Physiological Society
Integrating the Life Sciences from Molecule to Organism
9650 Rockville Pike
Bethesda, MD 20814
September 16, 2005
Ms. Beth Phillips
Office of Federal Financial Management
725 17th Street, NW
Washington, DC 20503
Dear Ms. Phillips:
I write to you on behalf of the American Physiological Society (APS). The APS is a professional society with more than 11,000 members who are active participants in the research community. We appreciate the opportunity to provide comments in response to the request for information from the Office for Science and Technology Policy (OSTP) and the National Institutes of Health (NIH) in the July 18, 2005 Federal Register (Vol. 70, Number 136, pg. 41220-41222). As a member of the Federation of American Societies for Experimental Biology (FASEB), the APS endorses FASEB's comments, submitted separately, on the Multiple Principle Investigators Request for Information.
As scientific advances increasingly require collaboration between investigators in diverse areas of research, the APS believes that it is important to recognize the unique contributions of multiple principal investigators (PIs) to research projects. By allowing multiple PIs on federal grants, the scientific community will be taking a positive step towards fostering communication between disciplines.
1) Statement of what constitutes a PI:
APS believes that in order for the multiple PI policy to succeed, the role of the PI must be clearly defined. Each PI should have a defined responsibility for some aspect(s) of the project and contribute creatively in a way that is critical to the success of the research. Participation in a multiple PI grant project should be in line with each investigator's current, demonstrable research interest, and should represent a major effort and not a side-involvement. Designation as a PI should require a minimum percent effort from all parties (approximately 20%). A researcher who contributes only a service or technique, however specialized, but no novel concept, should not be considered a PI. APS believes that there should be a limit on the number of PIs allowed per project, perhaps not more than 3 for individual investigator initiated grants (R01's, RFA's, etc.), as more than that would make efficient coordination and management unwieldy.
2) Designation of Contact PI:
APS is concerned that designation of a contact PI for each project implies that that person assumes more responsibility or leadership than the other PI(s). Given the largely electronic nature of communications, it should be possible to send all communication to all PIs. However, we realize that as a practical matter, each PI communicating directly with the agency in response to inquiries may cause confusion. We suggest that the contact PI be designated to respond to agency inquiries, but that any communications from the agency be sent electronically to all PIs, rather than distributed through the contact PI. This will ensure that all PIs are aware of all communications from the grant-making agency.
3) Application instructions for listing more than one PI:
Applications for multiple PI grants should include a rationale for the designation of more than one PI, a management plan and individual budgets for each PI. The rationale should include a description of the role of each PI. The management plan should include a process for resolving any disputes, and a plan for how decisions affecting the scientific direction of the project will be made. The individual budgets should reflect the anticipated allocation of the grant money, but there should also be a process put in place for reallocating funds as necessary, with the agreement of all PIs on the project. While the preparation of these documents may seem onerous, we believe that clear plans from the outset will ensure maximum transparency and facilitate open communication between all PIs and the grant-making agency.
4) PIs at different institutions:
APS supports collaboration of PIs in different departments and institutions through participation in multiple PI grants. The preparation of individual budgets at the outset of the grant application process will facilitate such collaboration. By preparing separate budgets, each institution or department will be able to determine their share of the indirect costs of the grant and recognize the participation of their faculty. The recognition of multiple PIs at different departments or institutions will allow a fair distribution of credit for important collaborations.
5) Access to award and peer review information:
APS believes that in order to foster fair and open collaboration, each PI needs full access to all peer review and award information.
6) Access to public data systems:
Public databases that list federal grants should allow identification of multiple PIs. The databases should properly credit each institution and department for faculty participation in multiple PI grants. For example, this could be facilitated by adding a PI-specific suffix to each multiple PI grant number.
7) Other Considerations:
The APS has worked for years to help NIH foster programs that supported the careers of young and new investigators. Currently the NIH's Center for Scientific Review recognizes such investigators in peer review of their grant applications at Study Section in an effort to promote those careers. If the multiple PI policy were to preclude such investigators from seeking such special review, that policy could undermine efforts to enrich the scientific community with entering scientists. Young scientists who work with an internationally recognized senior scientist are at particular risk even if they have been designated a "PI" in that reviewers of their subsequent individual grant applications would likely consider their having failed to show their own independence of their senior colleagues.
8) Other suggestions:
Regarding scientific review of multiple PI grants, the APS believes that each grant should be evaluated by only one study section. Given the diversity of scientific specialties that may be involved in multiple PI grants, this may require formation of special study sections staffed by pertinent experts.
In conclusion, the APS believes that allowing multiple PIs on federal grants will substantially benefit inter-disciplinary collaboration. This is an important policy change that we believe will allow scientists in all disciplines to take advantage of the best new technologies and ideas. Implementation of this new research model will be a challenge, and APS appreciates the efforts of OSTP and NIH as they work toward this goal.
Sincerely,
Douglas C. Eaton, Ph.D.
President
American Physiological Society