PI Effort at Multiple Sites

[Jerian Lind]

We have a PI for a study that is being conducted at multiple sites (network study).  Two of the sites are HCMC and UMMC.  Funding for the study is being awarded to UMN and HHRI (HCMC) separately, but the PI is the same person for both sites (he has appointments both here and there).  Effort will be based on enrollment.  Is there anything preventing the PI from certifying effort on the same study at multiple sites?  Has anyone else had this scenario?

[Anne Mockovak]

I always go under the assumption that we are only responsible for making sure the PI complies with our policies.  We don't have responsibility for another institution.  It's the PI's responsibility to juggle multiple appointments.  That said, I did have this scenario and all the PI's effort was booked on the University side regardless of the location of the subject.  The hospital salary for this particular PI was solely for patient care and not research so he didn't have any research effort to report through the hospital.  We made sure the hospital budget didn't include any time for his effort.

[march016]

Hi Jerian,

I reached out to David Hagen for his take on this and he provided the answer below...

If the PI has two separate appointments with two different entities, then there isn't a problem as long as the PI can differentiate whether they are seeing a patient as part of the HCMC award or as part of the UMMC award.  They have to be able to know that for other reasons too, such as billing, so I am assuming that tracking patients for each entity will be done by site (i.e. all patients enrolled at certain sites will belong to the HCMC award and all patients enrolled at other sites will belong to the U of M award)

As a side note, I think they are required to have an MOU in place between the two entities explaining the percent time or hours that they are working each entity (at least I know that is true if they have a dual appointment between the U and the VA), but that is really an HR issue.