Eligibility of Intramural Investigators for NIH Common Fund Awards

The NIH Common Fund is a series of cross-cutting programs that are collectively planned and implemented by the 27 Institutes and Centers with oversight and coordination from the Office of Strategic Coordination, Division of Program Coordination, Planning, and Strategic Coordination (DPCPSC). The overarching goal of the Common Fund is to stimulate research that has potential to transform the way research is conducted - either by providing transformative research infrastructure, by developing novel tools and technologies, by fostering innovation and innovative approaches to science, or by addressing previously intractable scientific problems in new ways. New Common Fund programs are selected by the NIH Leadership each year from a pool of possibilities submitted by the public, NIH staff, and extramural scientists.

IRP/ERP Competition for Common Fund

The Common Fund is a separate appropriation within the OD budget and is therefore not specifically designated as either intramural or extramural. The NIH Steering Committee recommended in June 2007 that the IRP be allowed to participate in Common Fund initiatives for which the scientific goals can be well served by IRP participation (see NOT-07-011). This will ensure that qualified researchers in the IRP are able to contribute to the goals of the programs and that the best science is supported.

Both intramural and extramural investigators are eligible to compete for most Common Fund programs. However, there may be circumstances in which the presence of a unique resource in the IRP will result in the IRP being funded without competition, or the IRP may be excluded from an initiative, as when the goals of the program are primarily directed toward extramural needs. Information on the eligibility of the intramural program to compete in a given initiative can be found in the “Eligibility” section of the Funding Opportunity Announcement (FOA).

Principles of competition with the Extramural Research Program (ERP)

Initiative Development

The default situation for Common Fund programs is that the IRP will be invited to compete with the ERP for initiatives, necessitating the following “firewalls” that must be erected early in the process to prevent inappropriate involvement of the IRP in initiative planning. The principle on which these firewalls are established is that, for the purposes of the NIH Common Fund, intramural investigators and extramural investigators must be treated equivalently:

• Intramural investigators who may potentially compete for funding should be treated in the same way as extramural investigators, i.e., if extramural advice is solicited, intramural investigators may also provide input. For example, intramural investigators may submit ideas for new programs but should not participate in Trans-NIH working groups that develop these ideas into specific initiatives or programs. Likewise, after awards have been issued, funded intramural investigators will be asked to participate in meetings of awardees but will not participate as Extramural Program Directors.
• An IC Director whose IRP is involved in a program must recuse him/herself from any budgetary discussions pertaining to the program as well as development of funding plans.

Application

All Common Fund initiatives for which the IRP can compete with the ERP will be announced through Funding Opportunity Announcements (FOAs). If an FOA allows competition from the IRP, it should list “eligible agencies of the federal government” under the list of eligible institutions/organizations in the Executive Summary. However, if this is not listed, interested investigators may contact the scientific/research contact listed in the FOA to inquire about eligibility.

IRP applications require the signature of the Institute’s Scientific Director. This signature represents institutional support for the project. If the request is successful, the project will be supported by allocations from the Common Fund. The funding period is typically 3-5 years.

Budget requests from federal agencies, including the NIH intramural program, may not include any salary and related fringe benefits for career, career conditional or other federal employees (civilian or uniformed service) with permanent appointments under existing position ceilings or any costs related to administrative or facilities support (equivalent to Facilities and Administrative costs).

In general, the requests will be limited to the costs required for carrying out the proposed work if those costs can be specifically identified with the Common Fund project. These costs may include salary for staff to be specifically hired under a temporary appointment for the project, consultant costs, equipment, supplies, travel, and other items typically listed under Other Expenses. While support for extramural collaborators may be requested in a separate grant application, funds can be requested for services by an external investigator or contractor as a subcontract/consortium including the applicable indirect (F&A) costs of the contractor/collaborating institution.

Justification must be provided for all requested support. In addition, justification must be included for Federal employees who will be committed to the project although no funds are requested in the application. This will allow the Scientific Review Group to evaluate the suitability of proposed staff to conduct the work.

Applicants should indicate the number of person-months devoted to the project, even if no funds are requested for salary and fringe benefits. Scientific Review Groups will evaluate the appropriateness of an IRP budget request for the work proposed and will therefore need to know the number of people involved in conducting the work.

Review

In general, requests from the IRP and grant applications from the extramural scientific community that are submitted for the same Common Fund funding opportunity announcement (FOA) will be evaluated together, on a competitive basis, through the NIH peer review system, and the NIH Center for Scientific Review (CSR) will manage these reviews. The evaluation of scientific and technical merit will be based on the review criteria presented in the relevant Common Fund FOA and use the standard scoring system.

Members of the NIH IRP may serve on a Scientific Review Group (SRG) evaluating responses to a Common Fund FOA that include an IRP request(s). IRP members may participate in the evaluation of any ERP Roadmap grant application (provided that conflicts of interest have been resolved) but may not participate in the evaluation of any IRP application. For IRP applications, the IRP reviewer will be asked to leave the room, just as extramural investigators are recused from reviewing applications from their institutions.

Post-Award

Intramural investigators who are funded via the Common Fund program cannot participate in post-award activities of the Common Fund Working Group, except in situations where the extramural grantees are also included. However, for initiatives where the IRP and ERP do not compete, the IRP is funded as a sole source service, and the PI’s input is critical to the Project Team administering the initiative, he/she can be included as a Project Team leader. In this situation, the IRP PI will be recused when financial or budgetary decisions are discussed by the Project Team.

Generally, the Midcourse Review, required of most NIH Common Fund programs, will be guided by rules for initial peer-review of applications in terms of conflicts of interest. The review process will involve IRP investigators and ERP investigators in the same way. The Midcourse Review expert panel should not include IRP investigators. However, in the case in which the initiative serves the IRP only, an IRP reviewer may be used if he/she is not from the IC funded by the Common Fund.