1. PHS 398 instructions allow for arrangements in which much of the work is done at a place other than the applicant organization if you explain and justify adequately.  Cf. Consortium/contractual arrangements:  "Explain the programmatic, fiscal, and administrative arrangements to be made between the applicant organization and the consortium organization(s). If consortium/contractual activities represent a significant portion of the overall project, explain why the applicant organization, rather than the ultimate performer of the activities, should be the grantee."

2.If the PI works only for you, she shouldn't be listed on the other organization's budget as if she were employed there.  A collaborator at the other organization should be named as the PI for that organization, and have responsibility for the subaward.  If assigning ther term "PI" to this other person is more than your PI can swallow, call the other person a coinvestigator or collaborator.

3.  Unless your PI is also employed by the other organization, the business about differing base salaries doesn't make sense.  PHS 398 instructions stipulate that the persons listed in the personnel section should be employed by the applicant organization.  The other organization should not list your employees on its budget as if they worked there.  If your plan is truly that if the grant is awarded, your employee will go to, say half time at your school and be employed by the other institution, say that in the justification--but for your own sakes, describe the arrangements you will make for benefits such as health insturance.

4. The alternative is to let the other organization submit the application with its own employee as PI and make a subaward to you.

5.  We encounter such requests 4 or 5 times a year: a faculty member employed by a neighboring institution who holds a faculty appointment at our school (but is not employed by us) wants to submit an application "through" our school.  We recently installed a policy that requires the PI not only to have a faculty appointment, but also to be a FT employee.  This has raised vehement, loud resistance from the small number of persons who want exceptions--"You're obstructing research!"--but so far the policy has held.  Such a person can find a collaborator who works for us to serve as the PI.

6. From similar inquiries I've made to this listserv, it does appear that some schools let persons they don't employ submit applications--someone, for example, who holds an unsalaried faculty appointment.  I don't think they do it "all the time," though.

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@HRINET.ORG]On Behalf
Of Donna Berger
Sent: Thursday, July 08, 2004 1:17 PM
To: xxxxxx@HRINET.ORG
Subject: [RESADM-L] Faculty member serving as PI on another
organization's R01

We have a faculty member who is conducting research in collaboration with
another institution on an NIH grant. She wants to submit an R01 through the
other organization naming herself as PI. Initially, the proposal (for 2.5M)
was to be submitted by us, but since much of the work will occur at the
other site, she is requesting that we become a subcontractor and that the
other organization take the lead.  The other organization wants to allocate
part of her time to the prime budget (theirs)  and part of her time to the
subcontract budget (ours).  In effect, she would be PI for the prime and
subaward.  To complicate matters further, her base salary here will be less
than the base salary used by the submitting institution. Has anyone ever
run into a situation like this before?  Aside from the fact that we have
been working on this for over a month and now the tables have turned, is
any of this kosher?? The other organization claims to do this sort of thing
all the time and wants to enter a consortial agreement with us.  Please
advise!

Donna Berger, Ph.D.
Coordinator, Academic Grants
Marist College
Phone: 845-575-3670

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