45.22 - Eligibility, Competency and Effort Requirements for Principal Investigators, Co-Principal Investigators, and/or Project Directors

A. Purpose. The purpose of this policy is to:

• Position the University PIs, and Co-PIs to reduce the institutional risk involved in accepting and carrying out a sponsored project, or in carrying out regulated activity within any project;
• Establish criteria permitting individuals to fulfill the role of PI or Co-PI on a sponsored project and/or project that includes a regulated activity; and
• Ensure that sponsored projects and regulated activities are conducted by those who have the requisite training, competencies, skills, commitment, and resources, as well as the appropriate relationship with the University.

As a condition of its acceptance of sponsored project awards from external sponsors, or its engagement in a project that involves a regulated activity, the University is obligated in its role as the recipient of the award and/or overseer of regulated activities to ensure that:

• Sponsored projects and/or other projects including regulated activities are adequately administered by the PI;
• Only individuals meeting the eligibility requirements of this policy are listed as PI or Co-PI(s), and proposed projects are submitted through the University (see APM 45.02), following approved University procedures in place at the time of the submittal;
• All proposals and sponsored projects, including those involving regulated activities, are reviewed and approved by the unit administrator (when applicable), dean, or delegate and, if it is an external proposal, by an authorized individual in the Office of Sponsored Programs acting on behalf of the University; and
• All submitted proposals or projects involving regulated activities meet the requirements of the sponsor and/or the University. If sponsor requirements are less restrictive than University policies, University policy shall take precedence.

B. Scope. This policy applies to all proposals for projects seeking monetary or non-monetary support that are submitted to external sponsors and for which, if awarded to the University of Idaho (University), they will be governed by a contract, grant, sub-agreement, cooperative agreement, or other binding agreement, and to all projects, irrespective of the source of funding or other support, including activities that are subject to federal, non-financial compliance regulations and are overseen at the University by the Institutional Review Board (IRB), Institutional Animal Care and Use Committee (IACUC), Institutional Biosafety Committee (IBC), another compliance board or compliance coordinator, and/or Export Controls (EC). This policy does not apply to consultant agreements or the procurement of goods or services from vendors

C. Definitions.

C-1. Principal Investigator (PI) or Project Director (PD): A PI or PD is the primary individual responsible for the preparation, conduct, and administration of a sponsored project (see C-4, below) or a project that includes a regulated activity (see C-5, below) to ensure it complies with applicable laws, regulations, and institutional policy governing such projects. More specifically, this individual is directly responsible and accountable to the University for the proper programmatic, scientific, technical and/or professional conduct of the project, and its financial and day-to-day management (see FSH 5100 H). The PI/PD retains the majority of the responsibility to meet the requirements of the award and/or aspects of a project that involve regulated activities. For this policy, the term PI will be used to indicate both PIs and PDs.

C-2. Co-Principal Investigator/Co-Investigator (Co-PI/Co-I) or Co-Project Directors (Co-PD): Co-PIs/Co-Is or Co-PDs are key personnel who have responsibilities similar to that of a PI. While the PI has ultimate responsibility for the project, the Co-PI/Co-I/Co-PD(s) are also obligated to ensure the project is conducted in compliance with applicable laws, regulations, and institutional policies governing the conduct of sponsored projects or other regulated activities. Specific responsibilities assigned to each Co-PI/Co-I/Co-PD(s) are defined within the proposal documents submitted to the sponsor. For this policy, the term Co-PI will be used to indicate Co-PIs, Co-Is and Co-PDs in internal the electronic research administration system. Note that senior key personnel may be defined in a role similar to a Co-PI or Co-PD, but are named specifically as senior key personnel in the agency-submitted proposal.

C-3. Faculty or Staff Participant: University faculty and staff may be involved in projects as key personnel without the same level of responsibilities as a PI or Co-PI. However, any faculty or staff member who is involved in a regulated activity (see C-5, below) is responsible for the appropriate conduct/performance of that activity, irrespective of whether he/she is a PI or Co-PI. Faculty and staff may participate in the activities of the sponsored project, may collect salary, and may have a role in project outputs (e.g., performer, instructor, author, patent holder). A faculty participant may also be referred to as a faculty investigator. Senior personnel and staff participants may also be referred to as professional staff or senior staff.

C-4. Sponsored Project: For this policy, a sponsored project is any project or portion of a project in which the University is engaged through its faculty, staff, or students that involves an interaction between the University and another party which may be an entity, unit, or individual inside or outside of the University. Normally, the agreement involves a transfer of funds, a non-monetary exchange, or payment for services and/or products. Sponsored projects include interactions such as awards, sub-awards, grants, research contracts, outreach contracts, instruction contracts, cooperative agreements, capacity building contracts, public service work, community service project agreements, class projects with communities, task orders, extension projects, etc. where the University is committed to delivering a service or product.

C-5. Regulated Activity: For this policy, a regulated activity is any project or portion of a project, in which the University is engaged through its faculty, staff, or students that is subject to one or more federal, non-financial compliance regulations. Such regulations may include (but are not limited to): human subject protection regulations (FSH 5200), animal care and use regulations (APM 45.01), biosafety and select agents regulations (APM 35.11), and export control regulations (APM 45.19). At the University, such activities are overseen by the IRB, IACUC, IBC, (FSH 1640.54, 1640.12, 1640.14) or EC.

D. Policy.

D-1. To ensure that sponsored projects and/or projects which include a regulated activity are conducted by those who have the requisite training and competencies and who have the appropriate relationship to the University of Idaho, PIs and Co-PIs must generally be employed by the University in a faculty or staff status.

Persons holding the following positions may be designated as PI or Co-PI in applications for externally sponsored funding or for other projects that require carrying out a regulated activity. The positions listed in categories i.-v. are defined in FSH 1565, Academic Ranks and Responsibilities. For each of these categories, the leaders of the appropriate unit(s), school(s), disciplinary or interdisciplinary program(s), and college(s) determine and approve the qualifications of the individual. Approval of eligibility and capacity is indicated by the electronic signature of the named unit leaders in the university’s electronic research administration system upon proposal submission or via prior approval:

i. All tenured and tenure-track university faculty, including - assistant, associate, and full professors; research faculty; extension faculty; librarian faculty; psychologist or licensed psychologist faculty; officer-education faculty; and university distinguished professors.

ii. All persons holding University-approved non-tenure track faculty appointments (temporary, full or part-time), including lecturers, visiting faculty, research faculty, non-tenure track Extension faculty, and clinical faculty.

iii. All persons holding faculty emeritus status at the University and not included under category ii. PIs in this category must work with a Co-PI from appointment types included in categories i. and ii. above and have the approval of their Chair and Dean (or equivalent) or have the approval from the Vice President for Research and Economic Development (VP ORED) to be PI without a Co-PI from categories i. and ii. above.

iv. All persons holding associated faculty titles, such as adjuncts and affiliates. Individuals in this category may only serve as a Co-PI and the PI must be from appointment types included in categories i. and ii. above.

v. All postdoctoral fellows who have the approval of their appropriate unit leaders. Individuals in this category can serve as the PI, but the postdoctoral fellow’s faculty mentor must be listed as a Co-PI.

vi. All Research Scientist II and III staff members who have the approval of their appropriate unit leaders may serve as PI. Research Scientist I staff may serve as Co-PI and must have the approval of their appropriate unit leaders and VP ORED or their delegate to serve as a PI.

vii. All staff members, who are not also students, and who have the approval of their appropriate unit leaders. Individuals in this category may serve as a Co-PI working with a PI from categories i and ii above. These individuals may serve as PI with approval from the VP ORED.

viii. Neither undergraduate nor graduate students may be designated as PIs or Co-PIs. When a sponsor’s program guidelines require the student to be listed as PI on the proposal application, the student’s mentor/advisor shall be the PI of record on the internal proposal application form in the University’s electronic research administration system and shall be responsible for the conduct and oversight of the project.

ix. For all other members of the University community, approval from the VP ORED or delegate is required. The VP ORED also retains the right to reject, suspend, or remove any proposed PI or Co-PI in applications for externally sponsored funding, based upon previous evidence of inadequate project or financial management. At their sole discretion, the VP ORED may waive for individuals who fall under categories iii.-viii. the requirement that such individuals have another University individual serve as Co-PI (see categories iii., v. and vi., above) or the requirement that such individuals have another University individual serve as PI (see category [iv.], above).

D-2. Special Eligibility Situations.

i. Non-US Persons: Non-US PIs and Co-PIs wishing to apply for sponsored funding, and who meet one of the general eligibility requirements listed above i.-vii., must also have the appropriate immigration status to participate in the proposed sponsored activity. Current regulations place severe penalties on non-U.S. persons who violate the terms and conditions of their immigration status and on PIs and universities that violate export control laws and regulations. These issues must be addressed if a non-immigrant investigator is to be included in a sponsored project.

For example, before beginning a new project or new employment, non-immigrants currently employed by the University in H-1B, O-1, TN or J-1 visa status should consult with Human Resources about changes that may be required as a result of the new project or employment H-1B, O-1 and TN visa status are employer-specific and job-specific; therefore, a change of employment may require a petition to US Citizenship and Immigration Services (USCIS) for new, amended, or concurrent employment authorization. In addition, J-1 Research Scholars and Professors are admitted to the U.S. to complete a specific objective, defined before issuance of the Certificate of Eligibility for Exchange Visitor (J-1) Status (Form DS-2019). Changes and additions to that objective will require review by the program sponsor before beginning a new project. These two cases point out the importance of clearly understanding an investigator’s immigration status before their involvement in a sponsored project or regulated activity.

To promote openness in research, the University generally does not accept sponsored projects that include citizenship-based restrictions on participation. In limited circumstances, and after review and approval by the VP ORED or designee, the University may engage in research in which the sponsor imposes citizenship restrictions that permit participation only by U.S. citizens and/or permanent residents (green card holders). Such restrictions are generally acceptable in connection with fellowship support for graduate and undergraduate students and may be acceptable, on a case-by-case basis, in connection with sponsored funding intended to advance the research careers of new faculty. International sponsors (e.g., European Union, international development bank, non-governmental organization, etc.) may have similar eligibility requirements; such requirements are also subject to review and approval by the VP ORED or designee.

In cases where U.S. permanent residence/citizenship is not a sponsor requirement (e.g., working with a faculty member from an international university on a non-governmental organization-sponsored project) and where the individual proposed for involvement meets the general eligibility requirements listed above i.-vii., they are eligible to participate in non-export-controlled sponsored projects. If the project involves export-controlled technologies and/or materials, non-U.S. persons may require licenses to work on the project. Normally, this is dealt with when the proposal is developed and moves through the approval process in the University’s electronic research administration system. The University does not guarantee that it will be able to obtain a license if required and reserves the right to fulfill export control regulations through other means, including the exclusion of the person for whom a license would be required from participation in the export-controlled project or portion of a project.

Additional information on immigrant and non-immigrant statuses in the U.S. may be obtained by contacting the University’s International Programs Office. When working internationally, it is expected that the PI or Co-PI will contact the Office of International Programs and inform them of the proposed effort.

ii. Directors of University Approved Cooperative Arrangements: In cases where administrative funding is provided by contributing members/organizations (such as cooperatives, special extension programs, etc.) and/or an individual has the responsibility and designated time set aside in their position description (FSH 3050) for the administration and management of sponsored projects or projects involving regulated activity, there is no need for a PI or Co-PI to request additional funding for project administration from the sponsor. Such arrangements must be articulated in a University-approved master agreement (one official agreement covering all projects for a given period) before submittal; or via the rare approval by the VP ORED when such an agreement is still under development.

iii. Federal Employees as Primary Principal Investigators or Project Directors for the University: Unless faculty rights and privileges have been contractually granted to them, federal employees are not eligible to serve in a PI or a project director role at the University. Federal employees may cooperate with or collaborate with University faculty within the limits imposed by applicable legislation and regulations and, in this capacity, may serve as Co-PI. The federal employee may participate in planning, conducting, and analyzing the research directed by a University PI, but cannot direct projects on behalf of the University. The University may subcontract with a federal agency (if allowable through applicable legislation and regulation) for research personnel, supplies, equipment, and other expenses directly related to the research. Salaries for permanent federal employees may not be provided.

E. Procedure.

Review of PI/co-PI eligibility is made by the Office of Sponsored Programs at the time of proposal review in the electronic research administration system. If it is determined that the person requesting to be PI/co-PI is not automatically eligible under the above policy they will be notified to complete a request for approval of eligibility to OSP who will coordinate with the VP OREDt or delegate. Such request shall consist of a TDNext ticket submission and include approval from the relevant unit leaders (i.e. chair and college dean or unit director) along with statement of competency and a current C.V.

F. Contact Information. Office of Sponsored Programs; osp@uidaho.edu; 208-885-6651

G. Related Policies. The roles of unit leaders (e.g., Chair, Head, Program Director, Dean, Provost, appropriate equivalent non-academic administrative unit leaders) and VP ORED concerning this policy, and sponsored projects, are outlined in FSH 5100 F and G.

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