Remembering back to my days as a PI, I can recall myself saying something like “yea, on my NIH grant…” when discussing my research. This may have been okay over coffee, but it is technically incorrect. We hear this confusion a lot. So, we thought it would be worthwhile to remind you about some of the respective roles of institutions and investigators working on an NIH award.
For the most part, NIH makes awards to institutions, not people. This may seem counterintuitive since the idea for the research may have come from the investigator. Why do we do it this way? The rules for all Federal awards- including uniform administrative requirements, cost principles, and audit requirements anticipate that an institution/organization carries out a Federal award as the “recipient” of the award. The institution designates individuals, including an “authorized organization representative” (AOR) the program director/principal investigator (PD/PI), to assume the responsibilities described below, in fulfilling the terms and conditions of their award. The NIH Grants Policy Statement (NIH GPS), which is a term and condition of all NIH awards, summarizes these responsibilities and the respective roles of the institutions and individuals.
Among other obligations, the applicant organization must certify, and in some cases submit assurances, that they comply with the public policy requirements provided in the NIH GPS. These requirements are intended to ensure fairness, equity, fiscal stewardship, and other protections in activities that receive NIH support. They include measures to promote objectivity in research, civil rights protections, human subjects protections, consideration of environmental impacts, animal welfare, compliance with PHS policies on research misconduct, maintaining a drug-free workplace, prohibitions on lobbying with Federal funds, and many others. While NIH maintains oversight of our awards, we entrust our recipient organizations with the responsibility and accountability for successfully administering their grant award, including prudent fiscal management and other requirements spelled out in the NIH GPS. The NIH Welcome Wagon letter also provides a concise overview of institutional responsibilities.
NIH staff work with designated AORs for compliance matters related to the award. Also known as the Signing Official within the eRA Commons, the AORs are pivotal partners with us, as they are the persons authorized to act for the institutions. They assume the obligations imposed by Federal laws, regulations, requirements, and conditions that apply to grant applications and awards. Further, they assure the materials submitted to NIH are the original work of the PD/PI as well as certify that the institution is accountable for the appropriate use of federal funds and performance of the grant-supported project.
We rely on our recipient institutions to be responsible stewards of taxpayer funds and to ensure the same of the PD/PIs identified on an application to intellectually and logistically direct the proposed research. The qualifications of the investigators are evaluated during peer review to ensure they have the appropriate expertise and skills to serve on the leadership team and execute the project before any funding is awarded. Key among their responsibilities, consistent with those of the institution, is fostering trust and transparency in the research enterprise. Generally achieved through ethical scientific conduct as provided in the NIH GPS, the investigators foster research integrity when they uphold shared values, adhere to requirements and policies for scientific practices, and maintain high standards of scientific rigor and transparency when proposing, conducting, and reporting research.
The designated PD/PIs closely partner with their institutional officials to ensure appropriate responsibility and accountability for the proper conduct of research. They collaborate when creating and maintaining technical and administrative reports, preparing justifications, as well as ensuring compliance with the financial and administrative aspects of the award. Importantly, the PD/PIs must appropriately acknowledge Federal support of their research in publications, announcements, news programs, and other media, including when they or their institutions issue statements, press releases, requests for proposals, bid invitations, and other documents describing projects or programs funded in whole or in part with Federal money.
The key to success in grants management is a close working relationship between institutional officials and investigators, and communication and coordination with NIH. If an investigator has questions about their roles and responsibilities on an NIH grant, their first stop should be the sponsored programs office at their institution. If there are questions about a specific grant award, we encourage you next to reach out to the assigned NIH program official for scientific and technical questions, or the grants management staff for issues related to its business and administrative aspects.
Interested in learning more about what happens when the status of a PI changes? See our Nexus post on Changing the Status of a PD/PI: Clarifying the NIH Prior Approval Policy.