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Principal Investigator Eligibility Policy
This policy establishes the eligibility requirements for and the duties and responsibilities of all Principal Investigators (PI) at Grand Valley State University (University). The policy also provides for the establishment of formal processes to request and approve exceptions to the PI eligibility requirements.
For each externally sponsored project, it is customary to designate as PI one person who bears ultimate responsibility for scientific, technical, and programmatic decisions, and all financial, administrative, and compliance matters relating to the project. It is the policy of Grand Valley State University that only eligible University faculty, staff, and trainees and appointees (when appropriate) may serve as the PI on externally sponsored projects to be carried out on behalf of the University.
Serving as the nominal project leader to lend credibility to a proposal while delegating PI responsibility to another person (i.e. “fronting” as the PI) is never permissible and is considered a violation of this policy.
PI eligibility is conferred in one of two ways: (1) automatically, by position, and (2) via special request, both subject to training as required by this policy.
- Automatic Eligibility: PI eligibility is automatically conferred upon tenured and tenure track faculty at the rank of Professor, Associate Professor, or Assistant Professor.
Special-Request Eligibility: If PI eligibility is not conferred automatically, it may be conferred by Special Request of the employee’s authorizing official (dean, provost, vice president) or their designee(s)). Certain non-academic units (e.g., the University Art Gallery, Small Business Development Center, Johnson Center for Philanthropy, Van Andel Global Trade Center) may request longterm PI status for the director, associate director, and other Administrative/Professionals (regular, full-time employees), as they deem appropriate. These personnel are all subject to standard Compliance and Training requirements for PI Eligibility.
- Fellowships and Training Opportunities
Trainees (typically graduate students and post-doctoral fellows) may be eligible to be PIs on fellowship and training programs when that designation is required by the funding agency as documented in a funding opportunity announcement and a PI-eligible faculty or staff member is identified and documented as their sponsor/mentor. In this circumstance, a trainee’s PI eligibility is conferred and verified by the applicable Department/Unit Head’s approval during the internal proposal-routing process. It is not necessary to document approval of trainee PI eligibility via Special Request.
Trainee PI status is consistent with the treatment of all Special Requests for PI eligibility, in that it is conferred on a case-by-case basis; it does not confer blanket PI eligibility status for any other externally sponsored projects.
Compliance and Training Requirements
However it is conferred, PI Eligibility Status is contingent upon the documented completion of all required compliance and sponsored-programs training. Training requirements, certification, and documentation are determined and administered collaboratively by the Vice Provost for Research Administration, the Office of Sponsored Programs, the Office of Research Compliance & Integrity, and the Controller.
This policy designates authority to the Vice Provost for Research and the Director of Sponsored Programs to establish such operational procedures as they deem necessary to implement this policy, and ensure operational efficiency, proper oversight of compliance and administration, and the success of externally sponsored projects at the University.
It is the responsibility of the Office of Sponsored Programs to review all proposals to fund externally sponsored projects to determine and document PI eligibility prior to proposal submission. Proposals put forward by individuals without documented PI eligibility will generally not be approved for submission. Awards resulting from proposals submitted by ineligible PIs who either knowingly or unwittingly circumvent the standard approval process will generally not be accepted by the University.
Responsibilities of All Principal Investigators
Although the University is legally responsible to the sponsor as the actual recipient of any externally sponsored award, the Principal Investigator (PI) is accountable for the proper fiscal management and conduct of the project. This includes managing the project within funding limitations and all of the terms of the award, assuring that the sponsor is notified when significant conditions related to project status change, and ensuring that all programmatic reporting requirements are met in a timely fashion. To assist PIs, the University provides supporting administrative services and has established procedures to help meet both sponsor and University requirements. While responsibility for the day-to-day management of project finances may be delegated to administrative or other staff, accountability for compliance with federal requirements, University policies, and sponsor requirements ultimately rests with the PI. The full cooperation and vigilance of the PI, along with the University, is necessary to maintain the stewardship role.
1. Preparation of Proposals
Principal Investigators have primary responsibility for planning and carrying out the preparation and submission of proposals for external support. Although PIs may have administrative staff to assist with the proposal-development process, they are ultimately responsible for the quality and scientific integrity of the proposal, and for understanding and complying with all University policies for managing external support.
a. Technical Proposal
The Principal Investigator is responsible for preparing the technical proposal.
b. Proposal Budget
The Principal Investigator prepares, or directly supervises the preparation of, all aspects of the proposed budget and budget justification. This responsibility includes coordination with Procurement Services and compliance with all procurement policies and procedures. It also includes identifying any requests and sufficient resources for cost sharing (including matching funds); the need for space or space modifications (including any accommodations for large and/or unusual equipment); and the need for outside collaborators (sub-recipients, contractors, consultants). The PI ensures all costs are allowable, allocable, and reasonable for the project in accordance with the federal cost principals set out in OMB 2 CFR 200, and that all proposals include full recovery of all anticipated project costs. Full recovery includes recovery of indirect costs at GVSU’s negotiated federal rate or (in the case of non-federal sponsors or federal training grants) the maximum rate allowed under published sponsor policy.
c. Regulatory Requirements
The PI is responsible for anticipating whether the research will involve human subjects, live animals as subjects, recombinant DNA, infectious agents, narcotics or biological toxins, human blood or body fluids, radioactive materials, hazardous materials, export controls, conflicts of interest, or other regulated activities requiring University review or clearance. The PI is responsible for preparing information and forms required for review by the University’s Office of Research Compliance & Integrity.
d. Project Approvals
The Principal Investigator prepares, or directly supervises the preparation of, and electronically signs internal proposal-approval forms, and requests required approvals in a timely fashion.
2. Acceptance of the Award
The PI is responsible for collaborating with the Office of Sponsored Programs in any negotiations with the sponsor relating to modifications of the project scope or budget or proposed terms and conditions of the award.
The Principal Investigator is responsible for reviewing and approving the award agreement, in conjunction with OSP, including the scope of work, budget, and the special terms and conditions of the award, and for managing the award in accordance therewith.
3. Conduct and Management of Award
The Principal Investigator is responsible for all actions required to manage and complete the scientific, programmatic, and financial aspects of the externally sponsored project in accordance with all of its terms and conditions, including the performance of all sub-recipients. The Principal Investigator is also responsible for the management of the award budget and expenditures in accordance with federal, GVSU, and sponsor requirements. This responsibility includes attesting to the allowability, allocability, and reasonableness of all expenditures. Principal investigators are responsible for routine monitoring of the status of grant accounts to prevent overdrafts and incorrect charges and to ensure that unallowable costs are not charged to an award.
The Principal Investigator is responsible for the timely submission of all required programmatic reports, interim and final. The information contained in such reports must be supported by adequate documentation. The Principal Investigator will provide copies of all required programmatic and progress reports to the OSP and the Grants Accounting office.
Externally Sponsored Project: All grants and cooperative agreements (direct assistance actions); all incoming or outgoing sub-recipient agreements or subawards (pass-through assistance actions); certain incoming or outgoing contracts (i.e., externally sponsored procurement actions), including direct contracts, service agreements, and consulting agreements; pass-through subcontracts and service agreements; and certain other agreements, including master collaboration agreements, material transfer agreements, and data-use agreements—whether funded or unfunded. Externally sponsored projects do not include purchasing agreements or philanthropic gifts.
Principal Investigator (PI): An individual with a formal affiliation with the University, normally an employee, who is or becomes eligible under this policy to submit a proposal for extramural support for a research, training, public-service, or other externally sponsored project, who personally participates in the project to a significant degree, and who has primary responsibility for the scientific, technical, programmatic, and administrative conduct and reporting of the project, including compliance and financial matters. A Principal Investigator who is the head of a training or other sponsored project may be known as a Project Director. For the purposes of this policy, the terms shall be considered equivalent. The University only recognizes one individual as the Principal Investigator and this individual must personally participate in the project to a significant degree.
Co-Investigator (Co-I): An investigator who will share responsibility for the scientific, technical, and/or administrative conduct and reporting of a research or sponsored project with the Principal Investigator. Each individual named as a Co-Principal Investigator at the University must meet the same eligibility requirements as a PI as noted above. There may be more than one Co-Principal Investigator, but one person is designated as the leader (PI) of the project. While the University allows this approach, not all sponsors allow Co-PI models. In certain cases, a sponsor (e.g., the National Institutes of Health—NIH) may allow a Multiple Principal Investigator model to be employed in a research or sponsored project. Such models feature multiple PIs who are expected to equally share responsibility for leadership of multidisciplinary and other types of “team science” projects that are not optimally served by the single Principal Investigator model. Such models typically require a single “Contact PI” and special justification in the form of a Multi-PI Plan that documents processes for project governance and resolution of conflicts.