Sponsor-Specific Guidance
All Investigators must comply with the University’s Policy on Conflicts of Interest in Research,
regardless of sponsor.
NIH grant Policy Statement (GPS) defines senior/key personnel as: “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.” For further details please reference ...
- Applicability: PHS, NIH, and most subordinate HHS agencies
- Policy: 42 CFR Part 50 Subpart F
- Who must disclose: Principal Investigators, Co-Investigators, Key Persons, and others who meet the PHS definition
- Effective date: August 25, 2011
DOE defines Senior/key personnel as “the PI; any other person who significantly influences the design, conduct, or reporting of a project funded under a DOE award; and any other person identified as senior/key personnel by the non-Federal entity in the application for financial assistance, approved budget, progress report, or any other report submitted to the DOE.”
“Investigator” means the principal Investigator (PI) and any person, regardless of
title or position, who is
responsible for the purpose, design, conduct, or reporting of a project funded by
DOE or proposed for
funding by DOE. The term “investigator” may include collaborators, consultants, or
graduate (Master’s
or PhD) students where individuals holding those positions otherwise meet the definition
of
investigator.
- Applicability: DOE and all subordinate offices, agencies, and national laboratories
- Policy: Amended DOE Interim Conflict of Interest Policy
- Who must disclose: Investigators who are planning to participate on, or are participating on, a DOE financial
assistance award, must disclose significant financial interests (and those of the investigator’s spouse and
dependent children) to the designated official(s) of the non-Federal entity. The disclosures must include
the certification language provided in the Interim COI Policy. See section IV(e)(4) of the Interim COI
Policy and Questions 31 and 32. - Effective date: August 17, 2026
NSF defines Senior Personnel as, “individuals designated by the proposer/awardee organization and approved by NSF, who contribute 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”.
- Applicability: NSF and all subordinate offices and agencies
- Policy: NSF Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 24-1) and 2 CFR part 200
- Who must disclose: Principal Investigators, Co-Investigators and other personnel who meet the NSF definition. (NSF I-Corps external personnel may be required to certify through MIT)
- Effective date: May 20, 2024
NASA defines a Principal Investigator (PI) as the individual whom an organization designates as having an appropriate level of authority and responsibility for the proper conduct of proposed work effort, including the appropriate use of funds and administrative requirements such as the submission of progress reports to the agency. Every proposal shall identify a PI who is responsible for the quality and direction of the proposed work effort and for the proper use of awarded funds regardless of whether the PI receives support through the award.
- Applicability: NASA and all subordinate offices and agencies
- Policy: NASA Grant and Cooperative Agreement Manual Section 29.7, Conflicts of Interest Policy (2024 Ed.)
- Who must disclose: Principal Investigators, Co-PIs, Key Persons, and others who meet the NASA definition
- Effective date: December 1, 2023