To be or not to be
“To be or not to be…” PI, Co-PI, Senior Personnel, or Key Personnel? That is the question that needs to be weighed at the proposal stage because it does have ramifications with the sponsor and with internal CSU processes. In a past blog “What’s in a name?” from April 9, 2019, the definitions of these personnel types were addressed:
Principal Investigator (PI): The individual primarily responsible for the content of a proposal and the conduct of an awarded project in accordance with sponsor requirements and in compliance with University policies and guidance. These responsibilities include (but are not limited to) financial oversight, submitting performance reports, providing project results (including deliverables), and completing internal processes such as project effort certification.
Project Director (PD): Project Director is a term that is used interchangeably with ‘PI’ and is also defined as a key person with responsibility for the information in a submitted proposal and the conduct of an awarded project.
Co-Investigator (Co-I): A member of the proposal team who is a critical “partner” for the conduct of the investigation through the contribution of expertise and/or capabilities. A Co-I will serve under the direction of the PI or a Co-PI.
Senior Personnel: Often the terms “senior” and “key” personnel are used interchangeably. A senior or key person is an individual who contributes to the scientific development or execution of the project in a substantive and measurable way.
Key Personnel: (a.k.a., senior personnel) Any project personnel who will have responsibility for the project in the role(s) of PI/PD, co-PI or co-investigator, collaborator, or any other significant contributor.
At proposal stage – Sponsors
Often the sponsoring agency will define the qualifications of a person who can serve as a PI.
Any of the personnel types above will generally need to provide documentation as part of the proposal submission such as biographical sketches, current and pending documents, and sponsor-specific documents like collaborators and other affiliations, work effort tables, etc.
At proposal stage – CSU
Additionally, institutions often define who can, as well as who cannot serve as a PI on a proposal. At CSU, PI eligibility is outlined in the PI eligibility guidance.
Any CSU employee who will have responsibility for the project in the role(s) of PI/PD, co-PI or co-investigator, collaborator, or other significant contributor and who is expected to be included in the submitted list of key personnel needs to be added to the Kuali Research Proposal Development (KR PD) record. They would have to have at least 1% minimum effort reflected in the proposed budget OR 1% minimum effort cost share proposed and documented in the KR PD record per the CSU policy for Cost Sharing for Sponsored Projects.
At award stage – Sponsors
Some sponsors require Just-in-Time documents for senior personnel such as NIH’s other support document, and NSF now requires ALL senior personnel to update and certify their biographical sketches and current and pending documents before an award is made to the institution.
At award stage – CSU
All senior personnel will have to have an approved Conflict of Interest (COI) disclosure prior to an account being created. Also, any documents in association with any applicable 1% minimum effort cost share will need to be fully signed prior to the account and the associated cost-share account being created.
Post-Award – Sponsors and CSU
Any changes to senior personnel after the award is made will generally require sponsor approval. Examples: reduction of the proposed effort, change of institution, replacement, change in scope of work, etc. Also, sponsors like NSF require that updates and certifications for ALL senior personnel documents be completed with each annual and final report.
Tracking these changes for senior personnel and making the appropriate requests to sponsors is time-consuming for PI, departmental, and central administrators. It can also have ramifications for effort certifications.
While it may be tempting to add more people as senior personnel, the decision to include them should be made based on each person’s level of responsibility for the project and the accountability expectations of the sponsor. Keep in mind that key personnel incur added responsibilities and documentation requirements during proposal stage, award, and post-award.
Only name people who are contributing to the scientific development or execution of the project in a substantive and measurable way and who are generally not easily replaceable without changing the scope or management of the work that is being proposed.
Blog post by Shannon Irey, OSP Training & Information Coordinator, and Chris Carsten OSP eRA Systems Officer