Update on Responsible Personnel (i.e., “Investigators”) on Proposals and Awards

Beginning October 1, 2022, all Senior/Key Personnel on proposals submitted to the Office of Sponsored Projects (OSP) on or after October 1, 2022, will, by default, be listed as “Responsible” for the design, conduct, or reporting of research. Senior/Key Personnel contribute to the scientific development or execution of a project in a substantive, measurable way and are therefore considered “Responsible Personnel” for proposal and award purposes.

In addition to the system default, Principal Investigators (PIs) are responsible for appropriately identifying any other individuals who are responsible for the design, conduct or reporting of research for each proposal and award. To assist with the appropriate identification of Responsible Personnel, i.e., “Investigators”, we have developed the following Matrix that summarizes titles and roles and offers guidance to PIs. Note that this Matrix is provided for guidance purposes only; PIs must still make a determination on a case-by-case basis.

Additional Information

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Senior/Key Personnel Definition

The PD/PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant.

Investigator Definition

“Investigator” means the Project Director or Principal Investigator and any other persons, regardless of title or position, who are responsible for the design, conduct, or reporting of research, or proposed for such funding, which may include, for example, collaborators or consultants.

Guidance for Determining Responsible Personnel (i.e., Investigators)

Note that this matrix is provided for guidance purposes only; PIs (not their business offices) must still make a determination on a case-by-case basis.

Title and/or Role	Responsible Personnel	Guidance
Principal Investigators (PI)/ Project Directors (PD)	Always	Includes multi-PIs.
Investigators, Co-Investigators	Always	Are named at the PD/PI’s discretion. Are involved with the PD/PI in the scientific development or execution of a project. May include research scientists, senior research scientists and senior postdoctoral associates, although this is not common.
Subrecipient PIs	Always	These individuals are always “Responsible.” Yale flows down COI requirements to subrecipients. For example, for PHS proposals and awards, Yale requires that Subrecipient Investigators comply with the FCOI policy of their home institution if a PHS-compliant FCOI policy exists, or the subrecipient institution must adopt a PHS-compliant FCOI policy.
Graduate or Postdoctoral Fellows paid on Graduate or Postdoctoral Fellowships (i.e., not research grants)	Always	Graduate or Postdoctoral Fellows are considered PIs on these awards and are therefore always “responsible.”
Sponsors/Mentors for Postdoctoral or Graduate Fellows	Always	F30 and F31 Applications call for Sponsors and Co-Sponsors. K-Awards call for “Mentors.” These individuals are always “Responsible.” This includes sponsors/mentors at other institutions.
Graduate or Postdoctoral Fellows paid on training grants	Rarely	The PI should determine if a Graduate or Postdoctoral Fellow is responsible for the design, conduct or reporting of research.
Postdoctoral Appointees paid on research grants	Sometimes	In most instances, Postdoctoral Appointees, while engaged in research, do so under the guidance and mentorship of a PI and do not meet the criteria necessary to be categorized as Responsible Personnel. The PI should determine if Postdoctoral Appointees are responsible for the design, conduct or reporting of research.
Graduate Students paid on research grants	Rarely	Only in rare circumstances would a graduate student meet the criteria of Responsible Personnel. They are in training and conduct research under the guidance and mentorship of a PI. The PI should determine if Graduate Students are responsible for the design, conduct or reporting of research.
Other Significant Contributors	Rarely	The PI should determine if Other Significant Contributors are responsible for the design, conduct or reporting of research.
Consultants	Rarely	Consultants are individuals who generally provide a ‘fee for service’ and do not typically conduct research. They may provide insight and expertise to the PI but independently are not responsible for the design, conduct or reporting of research. In most cases, they do not meet the definition of Responsible Personnel. The PI should determine if Consultants are responsible for the design, conduct or reporting of research.

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