Principal Investigator Eligibility

PI and Co-PI Guidelines for FAS and SEAS Researchers and Staff

For each sponsored award, it is customary to designate one person as the project’s Principal Investigator. This is the person who will bear primary responsibility for the project’s design, execution, and oversight as well as for all financial, administrative, and compliance matters.

Sponsors may use different terminology to refer to the leader or co-leaders of a project – Principal Investigator (PI), Project Director (PD), Co-Principal Investigator (Co-PI). In order to serve in any of these roles on an externally funded project, you will first need to determine your PI/Co-PI eligibility status.

 

What is the difference between a PI and a Co-PI?

Some sponsors allow more than one person to serve as Principal Investigator, often referred to as Co-Principal Investigators or Co-PIs, but will require one person to be designated as the primary point-of-contact for the award. This is the person who should be listed first as the lead PI in the proposal and in the Principal Investigator field in GMAS. Additional PIs, PDs, or Co-PIs should be noted in the proposal, where appropriate, and added to the GMAS Research Team.

 

Who can serve as a PI or Co-PI?

There are two distinct ways that an individual may be allowed to serve as a PI or Co-PI:

1) Eligibility through appointment*:

  • Continuous PI Rights are granted to teaching members of the Faculty (e.g. Assistant/Associate Professors and tenured Professors) and a select group of academic appointees
  • Limited PI Rights are granted to individuals who hold specific academic or staff appointments and seek grant support for a limited scope of activities directly related to their area of expertise

*Note: All individuals holding Continuous or Limited PI Rights are required to take the FAS and SEAS Update for Faculty and Principal Investigators on-line course in the Harvard Training Portal. The Office of Sponsored Programs (OSP) will not approve the submission of new or competitive renewal proposals, the establishment of new At-Risk accounts, or the acceptance of new or competitive renewal awards until the evidence of training completion is provided.

2) Eligibility through exception approved by the cognizant office or unit’s authorized approver

  • Exceptions are normally limited to a specific project or topic area
  • In rare cases, exceptions may be granted on a continuing basis if an individual has a demonstrated record of successful project leadership and does not require significant oversight or departmental resources (space, administrative/financial support, etc.)

Please refer to the PI and Co-PI Rights Eligibility by Appointment/Position Matrix for a list of the academic appointments and staff positions granted Continuous or Limited PI Rights. Holders of appointments or positions not listed in the matrix who wish to serve as PI or Co-PI must submit an exception request.

 

How to Request Exceptional PI or Co-PI Rights

Whenever possible, researchers who do not hold Continuous or Limited PI Rights should partner with individuals who do hold PI Rights to produce a collaborative proposal. If this arrangement is not possible, approval must be sought to serve as PI or Co-PI by completing the following steps.

 

Requests should be initiated as soon as the need for Exceptional PI/Co-PI Rights has been identified but no later than ten (10) days prior to the sponsor’s deadline.

 

Process Steps:

1) Download and complete the PI Rights Questionnaire

 

2)Complete the FAS and SEAS Update for Faculty and Principal Investigators course in the Harvard Training Portal and save a copy of the course certificate. If the course has already been completed once, it does not need to be taken again when requesting additional PI or Co-PI Rights. Simply submit a copy of the previous completion certificate with the questionnaire.

 

3) Once the questionnaire and training have been completed, the form must be signed by the requestor’s FAS Department Chair, Center Director, SEAS Area Chair, or equivalent approver

 

4) Submit the signed form, along with a current CV and a list of current grants and pending proposals to the appropriate authorized approver:

 
School/Division/Unit Contact Email
FAS Science Division Zoe Fonseca-Kelly zoefonseca-kelly@fas.harvard.edu
FAS Social Science Division Richa Mishra richa_mishra@harvard.edu
FAS Arts & Humanities Division (interim contacts as of May 2021)

Diane Schneeberger (departments with names starting with A-H)

Zoe Fonseca-Kelly (departments with names starting with L-T)

dls@seas.harvard.edu

zoefonseca-kelly@fas.harvard.edu

School of Engineering and Applied Sciences (SEAS) Diane Schneeberger dls@seas.harvard.edu
Graduate School of Arts & Sciences (GSAS) Allen Aloise aloise@fas.harvard.edu
Harvard College Rakesh Khurana rkhurana@hbs.edu
Harvard College Library Martha Whitehead martha_whitehead@harvard.edu
Other Contact RAS for assistance  

If approved, a copy of the fully signed form will be returned to the department and the form should be uploaded to GMAS when the proposal is locked and routed for review by OSP and/or RAS.

Exception requests are carefully considered and are not automatically guaranteed. Sample reasons an exception may be approved include, but are not limited to:

  1. When a grant program states that the Project Lead/PI must be someone with an appointment title that does not normally hold continuous or limited PI Rights.
  2. When a grant program will only consider projects with a single PI and therefore partnering with another individual is not an option.
  3. When there is no ladder faculty member in the department conducting similar research who can reasonably be asked to serve as the lead PI of the proposed project.
  4. When the work is to be conducted at a remote field sight where the exception requestor will be the sole senior person on site.
  5. When the purpose of the exception is to allow a lecturer who will be advising a senior thesis writer, whose work involves human subjects, to sign off on the needed human subjects protocols.

 

What is a Co-Investigator and Is Approval Needed to Be One?

Sponsors may use the Co-Investigator (Co-I) role to classify individuals who will work closely with the project team in the development or execution of the project but do not share the same level of project responsibility and oversight borne by a PI or Co-PI.

Individuals who are not eligible, either by appointment or exception, to serve as PI or Co-PI may be listed as Co-Investigator, provided they meet the sponsor’s definition of this role and hold a current active Harvard appointment. An exception to serve as Co-Investigator does not need to be sought from an authorized approver, provided the lead Harvard PI agrees with the Co-I designation.

Required Disclosures for PIs, Co-PIs, and Co-Investigators

Researchers serving in the following roles on National Institutes of Health (NIH) and National Science Foundation (NSF) projects are required to internally disclose their financial interests in the University’s Outside Activities and Interests Reporting (OAIR) system:

  • Principal Investigators on proposal submissions to NIH and NSF
  • Co-Principal Investigators on proposal submissions to NSF
  • Co-Investigators on proposal submissions to NIH

To trigger the creation of a certification record in OAIR for researchers who are not normally required to submit annual disclosures under the University’s Conflict of Interest policy (i.e. anyone who is not a Harvard faculty member), the proposal record must first be created in GMAS. All Harvard PIs, Co-PIs, and Co-Investigators must be designated as Investigators by answering Yes to the Investigator question when adding them to the GMAS Research Team. Once GMAS passes the information to OAIR, the Investigator will receive an email from oair@harvard.edu with a link to their required certification for that project.

For more information regarding financial disclosure requirements, please consult the Conflict of Interest page of the RAS website.

Student and Postdoctoral Researchers

Student and postdoctoral researchers are not typically PI/Co-PI eligible unless they fall under one of the following two notable exceptions:

1) Graduate and postdoctoral fellowship applications

  • Many graduate and postdoctoral fellowship programs require the student or postdoc to be assigned the PI role on the application. As long as the fellowship requires designation of a faculty mentor/sponsor responsible for oversight, PI Rights do not need to be formally requested.

2) NSF Doctoral Dissertation Research Improvement Grant (DDRIG) and Doctoral Dissertation Improvement Grant (DDIG) proposals or equivalent

  • NSF DDRIG and DDIG applications require the faculty mentor to serve as PI and the graduate student to serve as Co-PI. Exceptional Co-PI Rights do not need to be formally requested for these proposals.

All students and postdoctoral researchers submitting fellowship or NSF DDRIG/DDIG applications as a PI or Co-PI must take the FAS and SEAS Update for Faculty and Principal Investigators training course.

PI/Co-PI designation for the purposes of a fellowship or NSF DDRIG or DDIG application does not grant that individual the authority to serve as PI or Co-PI on other types of proposals. Reach out to your RAS Pre-Award contact if you have questions about whether PI or Co-PI Rights are needed for a specific application for graduate or postdoctoral funding.

If a student has a larger scale research project that does not fall under one of the two exceptions noted above, they must partner with a faculty member who agrees to serve as project PI. When this happens, the faculty PI will be responsible for project supervision, oversight, and reporting. When a faculty member PI signs off on a student-led project in GMAS, they are confirming their understanding of these expectations.

PI Rights for Human Subjects and Vertebrate Animals Protocols

Individuals who hold PI Rights within the FAS are eligible to serve as PI on human subject IRB and vertebrate animal IACUC protocols.

Those who are not PI eligible, including students, may still serve as a PI on an IRB application however there must also be a faculty sponsor listed. Read more about IRB PI Eligibility on the CUHS website.

Individuals who are not PI eligible may, on rare occasion, be authorized to serve as the PI on an IACUC protocol if there is a compelling justification. The Department Chair or Center Director can forward such a request to iacuc@fas.harvard.edu.

PI or Co-PI Status for Non-Harvard Researchers

FAS and SEAS do not delegate PI or Co-PI responsibilities to individuals over whom it has little or no authority. As such, non-Harvard researchers may not be listed as PI, Co-PI, Co-I, or equivalent in a Harvard proposal unless they fall into one of the following two categories:

 

1) Subaward personnel

  • Even though subaward personnel may be listed as PI or Co-PI on a Harvard proposal, the right to serve as PI or Co-PI must be granted to them by their home institutions. A Statement of Intent signed by a subrecipient’s institutional official serves as confirmation that personnel named as PI or Co-PI are approved to lead the project at their institution.
  • Harvard’s oversight and authority over subrecipient personnel will be governed by the terms of the subaward agreement

2) Sponsor-required exceptions to satisfy the requirements of a specific program announcement

  • For example, the NSF GOALI (Grant Opportunities for Academic Liaison with Industry) program requires that a Co-PI from an industry partner institution be listed on the project
  • If you are responding to a funding announcement that includes this type of requirement, please reach out to your RAS Pre-Award contact with questions about PI or Co-PI eligibility

PI and Co-PI Rights Eligibility by Appointment/Position Matrix

Click here for a printable PDF version of the matrix

 

PI/Co-PI Rights on a Continuous Basis

PI/Co-PI Rights with Limitations

PI/Co-PI Rights Must Be Granted

 

 

 

Additional Information

 

Faculty and Teaching Appointments

 

 

 

 

Professors (including Professors Emeriti)

X

 

 

 

Assistant and Associate Professors

X

 

 

 

Research Professors

X

 

 

 

Professors of the Practice (full time)

X

 

 

 

Professors in Residence

X

 

 

 

Senior Lecturers

X

 

 

 

Lecturers

 

 

X

 

Senior Preceptors and Preceptors

 

 

X

 

College Fellows

 

 

X

 

Benjamin Peirce Fellows (Department of Mathematics)

X

 

 

 

Faculty holding PI Rights at other Harvard schools [1]

X

 

 

With documented notification from individual’s home department

 

Research and Academic Appointments

 

 

 

 

Junior Fellows in the Society of Fellows

X

 

 

With approval of Society of Fellows Chairperson

Rowland Fellows

X

 

 

With approval of Rowland Institute Director

John Harvard Distinguished Science Fellows

X

 

 

With approval of JHDSF Program Director

Senior Research Fellows

 

X

 

Limited to area of expertise specified in appointment letter

Senior Research Scientists/Senior Research Scholars

X

 

 

 

Research Scientists/Research Scholars

 

X

X

PI Rights require approval; may serve as Co-PI without requesting exceptional Co-PI Rights if PI-eligible faculty member serves as PI on project

Research Associates

 

X

X

PI Rights require approval; may serve as Co-PI without requesting exceptional Co-PI Rights if PI-eligible faculty member serves as PI on project

Postdoctoral Associates/Fellows [2]

 

X

X

Approval required to serve as PI on projects that do not require a faculty mentor; may serve as PI on fellowships that require a faculty mentor

Graduate Students [2]

 

X

X

Approval required to serve as PI on projects that do not require a faculty mentor; may serve as PI on fellowships that require a faculty mentor

 

Library and Museum/Collections Staff

 

 

 

 

Senior Librarians and Library Curators

 

X

 

With approval of Harvard College Librarian, Senior Librarians and Curators may serve as PI on projects directly related to defraying costs of maintaining and/or digitizing collections

Museum and Collections Curators

 

X

 

On projects directly related to museum and botanical collections (e.g. conservation or exhibition of collections)

 

Other Professional Staff

 

 

 

 

Executive Directors, Directors, and Associate/Assistant Directors in FAS departments, centers, and institutes

 

X

 

On grants for general operations, permanent endowment, physical plant, administrative projects, outreach/continuing education programs for the general public, and support of non-degree instructional programs

Center Directors (Division of Science)

 

X

 

On equipment/fabrication grants and conference grants directly related to the center’s mission

All Other Appointments/Positions Not Listed Above

 

 

X

Justification to serve as PI or Co-PI must be compelling

 

[1] Links to other Harvard schools’ policies on PI Eligibility: Medical School, T.H. Chan School of Public Health, Graduate School of Education

[2] See Student and Postdoctoral Researchers section for more information