I agree with your PI about having them appear as Key.  But if this is a modular grant, I'm more concerned about how reviewers will view the percent effort that doesn't seem to be reflected in the overall total budget request.  Unless there is clear explanation, people working for no money can raise serious red flags for reviewers.  Also...find out if the % effort mentioned in these letters is being driven more by some threshold policy at their institution than by the actual requirements of the project.

Would it be better, or more legit, if you made this a consortium agreement?  This way, the foreign individuals would be identified within the total cost of the sub-contract.  This might also solve your responsibilities re the foreign institution's cost sharing/effort system.

Charlie

At 03:01 PM 6/9/2005, you wrote:
>Getting back to a discussion from last week -
>
> From NIH398: Key Personnel must devote measurable effort to the project whether or not salaries are requested. "Zero percent" effort or "as needed" are not acceptable levels of involvement for those designated as Key Personnel.
>
>Does measurable effort translate to an auditable effort report?
>If so, then my understanding would be that salaries that are not requested for % effort commitment means that the effort must be cost shared and verified through an effort report.
>
>My specific situation is with an NIH proposal that includes several foreign collaborators who are not requesting compensation for their effort but including a specific % effort commitment in their letters of collaboration. Unless their organizations would be cost sharing this, there will be no "measurable effort." I am trying to convince the PI to list them as Other Significant Contributors, however, he is concerned that category might signal to the reviewers that they are less invested in the project.
>
>Comments?
>
>Doris
>
>
>Evelyn J. Ford wrote:
>>Our understanding of Key Personnel for purposes of reporting on the PHS2590 Key Personnel report is that anyone identified as Key Personnel on form page 2 of the competing application should be listed here.This includes salaried and unsalaried individuals who have */any measurable /*effort, regardless of how the %age. We don't list anyone who does not have measurable effort as they are now officially classified as Other Significant Contributors (OSC).
>>It's our interpretation that Key Personnel listed in the NGA need to be addressed in the response to SNAP Q2 (significant change in effort -- reduction greater than 25%), but that */all /*Key Personnel as originally listed on form page 2 of the application need to be included in the Personnel Report unless they now meet the definition of OSC.
>>We try to discourage PIs from listing grad students, post-docs, etc., as Key Personnel when proposals are submitted, but some are adamant about this. If they do wish to list them, then they are included on the PHS2590 Key Personnel Report page. I can only hope that NIH doesn't start listing them by name in the NGAs!
>>-- Evelyn
>>*------------------------------------------------------------------
>>*Evelyn J. Ford, Associate Director
>>Office of Research Support Services
>>School of Medicine, University of Pennsylvania
>>270 Anatomy-Chemistry
>>Philadelphia PA 19106-6061
>>voice *215.573.1395*      fax *215.573.8802
>>xxxxxx@mail.med.upenn.edu
>>http://www.med.upenn.edu/orss/
>>http://www.med.upenn.edu/research/penn/*
>>
>>At 04:59 PM 6/1/2005 -0400, Susan Burke wrote:
>>
>>>Eleanor-
>>>Key personnel, for the purpose of reporting, are those listed in the NGA.
>>>Susan
>>>
>>>--
>>>Susan B. Burke
>>>Associate Director
>>>NYU Office of Sponsored Programs
>>>15 Washington Place, 1-H
>>>New York, NY 10003
>>>telephone: 212-998-2017
>>>fax: 212-995-4029
>>
>>At 04:13 PM 6/1/2005 -0400, Eleanor Cicinsky wrote:
>>
>>>Hi,
>>>
>>>How do you determine who key personnel are for this report to NIH. We have listed personnel with significant effort, not just those who are PIs, Co-PIs or faculty associates.
>>>
>>>NIH has not come back to us to re-do the form if we list Post Docs, Graduate Students or anyone who is working on the project more than 25%.
>>>
>>>What has been your experience?
>>>
>>>Eleanor M. Cicinsky
>>>Director, PreAward Sponsored Projects Administration
>>>Temple University,  406 USB, 083-45
>>>1601 N. Broad Street
>>>Philadelphia, PA  19122
>>>(Ph)  215.204.8691
>>>(Fx)  215.204.7486
>>>(Em) xxxxxx@temple.edu <mailto:xxxxxx@temple.edu>
>>>(Web) http://www.research.temple.edu
>>
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>
>--
>Doris A. Oravec
>Contract and Grant Specialist
>Office of Research & Sponsored Programs
>Lehigh University
>526 Brodhead Avenue 23B
>Bethlehem, PA 18015-3046
>Phone: 610-758-3023
>Fax: 610-758-5994
>Email: xxxxxx@lehigh.edu
>
>"That's DAO for short"
>
>
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