You've hit the nail square on the head. A consultant by definition is not project personnel - they're not employed by the proposing institution, and their role is effectively nominal. They provide advice, expertise, troubleshooting, etc., on an occasional or ad-hoc basis.
A co-PI, by contrast (as defined in the PAPPG, https://new.nsf.gov/policies/pappg/23-1/ch-2-exhibit-3), is someone who contributes "in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award."
If that doesn't convince your PI to change their mind, you should point out to them that by making the consultant a co-PI, they're telling NSF that this person is essential to the success of the project - so much so that, if they quit the project, it wouldn't succeed - and your PI would have to get permission from NSF before they could replace the consultant with someone else. If they're just a consultant, then no permission is required.
------------------------------
Michael Spires
Research Development Officer
Oakland University
Rochester, MI
(he/him)
mspires@oakland.edu------------------------------
Original Message:
Sent: 01-09-2024 09:33
From: Anonymous Member
Subject: NSF submission with consultant as co-PI?
This message was posted by a user wishing to remain anonymous
Dear Cayuse community,
A faculty member at my institution wants to list a consultant as a co-PI on an NSF submission. I disagree and think a consultant should not be considered a PI, since they're not a true collaborator on the project, but someone hired to assist with work we can't do internally. I'd appreciate any thoughts from the group.