Intramural / Extramural 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 are they allowed to receive monetary support from the grant. They may serve as an unfunded co-PI on a grant submitted by an extramural applicant under the leadership of an extramural PI. 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, such as the use of the cooperative agreement award mechanism (UO1 activity code), 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, as co-PI, or unpaid consultants on extramural grants where they do not serve as key personnel on the extramural award. 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.

Researchers are advised to consider the guidance on inappropriate foreign collaborations of any kind prior to engaging in any of the above activities with a foreign entity.

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
Revised: August 18, 2020

1. Sourcebook: Activities with Outside Organizations
2. PHS Grants Policy Statement, Chapter 7
3. NIH Manual Chapter 54204/6003-1
4. NIH Guidelines for the Conduct of Research
5. NIH Manual Chapter 2300-308-1