Comment Letter

Establishment_of_Multiple_Principal_Investigator_Awards

This document is a formal letter from Anthony P. DeCrappeo, President of the Council on Governmental Relations (COGR), addressed to the National Institutes of Health (NIH) regarding the establishment of Multiple Principal Investigator (PI) Awards. The letter acknowledges and commends the NIH’s initiative to adopt a multiple PI model to better support team science, viewing it as a constructive response to the complexities of collaborative research. COGR emphasizes the importance of transparent recognition and allocation of credit for all investigators involved, particularly through expanding the use of systems like eRA Commons and CRISP for documentation and information access.

The letter provides detailed feedback on various aspects of the new policy as outlined in NIH’s policy overview and FAQs. Key recommendations include clarifying the shared responsibilities of PIs, ensuring institutional input into decision-making, and listing key personnel alongside PIs to properly reflect intellectual contributions. COGR also raises concerns about fund allocation and reallocation processes, the administrative burden posed by the designation of a “contact PI,” and the peer review process’s role in evaluating leadership plans and model selection. The organization urges NIH to reassess certain administrative requirements, monitor the pilot period for impact and fairness, and improve reporting tools for research activity analysis. Overall, COGR expresses support for the multiple PI initiative while advocating for modifications to enhance clarity, equity, and administrative efficiency in the implementation of the policy.