Funding of Intramural Research
Program/Extramural Research Program
Collaborations
TO:
|
All Intramural
Staff
|
FROM:
|
Michael M. Gottesman,
M.D.
Deputy Director for Intramural Research, NIH
|
SUBJECT:
|
Funding of
Intramural/Extramural Collaborations
|
Collaborations between intramural and
extramural scientists are strongly encouraged, but the nature of
these collaborations must be clear to assure proper management of NIH
resources, and appropriate conflict of interest statutes must be
observed1.
- FOR SCIENTISTS PAID WITH INTRAMURAL
FUNDS
Grant Writing:
The main purpose of this memorandum is to remind everyone in the
intramural program that scientists paid with intramural funds may
not receive salary support or any other funds from NIH extramural
grants, either as principal investigators, other key staff, or as
consultants2.
During the time in which scientists are paid with intramural
funds, they may not serve as principal investigators on NIH
grants, nor may they write an NIH grant application as an official
duty activity, even if they receive no money from the grant.
However, scientists may prepare grant applications on their own
time for submission by a non-Federal organization for research
which will commence after they leave Federal
employment3.
Collaboration:
Collaboration involves a significant contribution to the
conceptualization, design, execution or interpretation of the
research study. Simply providing unique biological materials, such
as cell lines, antibodies, and probes, does not constitute a
collaboration4.
NIH scientists may serve as unpaid collaborators or unpaid
consultants on extramural grants. In these cases, a formal letter
from the intramural scientist must be included as part of the
grant application with a copy of this
letter sent to the Scientific Director. The letter should be
limited to a description of the intramural scientist's
collaborative work under the grant. The grant applicant is
responsible for writing the section of the grant that describes
the proposed collaboration within the grant, which the NIH
investigator should see and approve.
Cooperative Agreements:
In some cases the work of the intramural scientist is such a
substantial part of the proposal that the award may need to be
managed as a cooperative agreement. Circumstances defining when a
grant should be managed as a cooperative agreement are defined on
the attached document entitled "Cooperative
Agreements". If an intramural
scientist believes that his/her contribution requires a
cooperative agreement, the Scientific Director should be alerted
when the letter of collaboration is submitted, and, if
appropriate, the Scientific Director should notify the grants
management office of their Institute or Center about the nature of
the collaboration.
- GUEST RESEARCHERS
Guest Researchers at the NIH are not paid with NIH
intramural funds and are working in the intramural program on
projects of their own choosing; however they may be involved in
NIH-funded extramural projects. Any use of NIH intramural
facilities to conduct research supported by NIH, or other federal
extramural grants, must be approved in advance by the Scientific
Director who will notify the grants management office of the
Institute/Center or the federal granting agency providing the
funding, if such use requires a cooperative agreement.
- SPECIAL VOLUNTEERS
Special Volunteers, by definition, perform services for
the NIH on their own time, and not associated with their outside
employment5.
Scientific Directors must be sure there is no conflict of interest
such as would occur if support comes from organizations that do
business with the NIH or are currently receiving grants from the
NIH. If questions arise, the Scientific Director should consult
with the Institute Deputy Ethics Counselor, usually the Institute
Director, and the NIH Legal Advisor prior to accepting volunteer
services from individuals receiving compensation from outside
organizations.
Although these rules are complex, continued
public support of our research depends on appropriate stewardship of
federal funds.
/s/
Michael M. Gottesman, M.D.
December 1, 1999
1
2 PHS
Grants Policy Statement, Chapter 7:
http://www.nih.gov/grants/policy/gps/7costs.htm
3
NIH Manual Chapter
54204/6003-1
http://www3.od.nih.gov/oma/manualchapters/contracts/6003-1
4 NIH
Guidelines for the Conduct of Research:
http://www.nih.gov/campus/irnews/guidelines.htm
5 NIH
Manual Chapter 2300-308-1: http://www1.od.nih.gov/oma/manualchapters/person/2300-308-1/
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