Policy on Role and Eligibility of Principal Investigators

Principal Investigators (PIs) are, along with all members of the Faculty, responsible for determining the intellectual and logistical direction of research and scholarship, and for the training of graduate students and postdoctoral fellows.

A PI bears a number of responsibilities related to sponsored projects, typically conducting work for which external funding has been awarded. In a legal sense, externally sponsored projects are actually contractual agreements between a sponsor and the University. In order for the University to fulfill its obligations under such agreements, it relies on the PI to fulfill their role responsibly.

The PI has administrative responsibilities such as assuring that expenditures are made for the intended purpose of the project and in accordance with sponsor requirements, university policy and procedures, and any governmental regulations. The PI must comply with the technical requirements of awards such as any and all approvals (e.g. IRB, IACUC, Recombinant DNA, etc.) and timely completion of periodic and final narrative reports on the progress of the project and overseeing others who participate on the project, including university personnel, consultants, and subcontractors.  While a PI may delegate administrative responsibilities to another individual, ultimately the PI remains fully responsible for all charges, changes, and conduct of the funded project.

To encourage and accommodate multidisciplinary “team science” approaches to complex research problems, the National Institutes of Health has begun to formally allow more than one PI on a single research award. Each PI in a multiple PI award shares the responsibility and authority for leading and directing the funded project as “equals.” The presence of more than one identified PI diminishes neither the responsibility nor the accountability of any individual PI. The first PI serves as the contact PI to the sponsoring agency.

Eligibility to serve as a PI is a privilege limited to those with appropriate qualifications and appointment at the University. It is Tufts University policy that only those holding appropriate appointments as on-going, full-time employees serve as PIs since there must be direct accountability to the University, in addition to the external sponsor and any governmental regulators.

The following guidelines establish the qualifications for PI status:

1. Individual full-time University employees with the following appointment titles are eligible to serve as a PI:

• Professor, Research Professor, or Clinical Professor
• Associate Professor, Research Associate Professor, or Clinical Associate Professor
• Assistant Professor, Research Assistant Professor, or Clinical Assistant Professor
• Senior Scientist, Scientist I, II, or III (HNRC only)
• Librarian, Associate Librarian, or Assistant Librarian

2. Individuals appointed with titles such as Research Associate, Postdoctoral Fellow or Graduate student are not eligible to serve as a PI unless the sponsor award is specifically directed at such individuals (such as a fellowship application) and appropriate faculty supervision is assured, by a member of the Tufts Faculty who is eligible to serve as a PI.

Other individuals may serve as a PI, but only on an exceptional basis. Approval may be granted by the Vice Provost upon the written recommendation of the appropriate Academic Departmental Chair and with the signed concurrence from the appropriate Dean.  The recommendation is to be in the form of a letter of justification addressed to the Vice Provost. If approval is granted, a funding proposal may be submitted.

Exceptions to this policy may only be made on the basis of the particular facts involved and not as a routine basis. If granted, approval will be for a specific project duration, and will allow the PI to submit a given project to multiple sponsors for funding. The PI applicant must have the necessary experience and independence to compete for his/her own sponsored program and to administer the project should it be funded, as judged by the Academic Departmental Chair and Dean. Assurances must be given that necessary space or other resources or support will be provided for the length of the specific project and that, should the PI leave Tufts without transfer of the award to a new institution, the sponsoring department will either plan to terminate the project or replace the PI for completion of the University’s obligations to the sponsor. A plan should be developed for administering the sponsored project and should, at a minimum, include the identification of a specific individual with appropriate qualifications who will assume the responsibilities of PI to bring the project to a close.

For the purpose of clarity, the following five categories describe groups of individuals most likely to seek exceptional approval following the process described above.

3. Individual full-time University employees appointed as an Instructor or Lecturer.

4. Individual part-time University employees appointed with position titles in categories “a” and “c,” above.

5. Individual University employees appointed as professional staff to direct research projects in specialized fields that fall outside the typical academic departmental structure, such as those employed in a Center or Institute (e.g. Feinstein International Center, Global Development and Environment Institute, etc.).

6. Individual University employees with administrative position titles on occasion may serve as a PI, limited to projects related to an individual’s official duties and which enhance the mission of the University (e.g. a Student Aid Grant administrated by a senior staff member, a Public Safety Grant administered by the Director of Public and Environmental Safety, or a Massachusetts Campus Compact Grant administered by a Program Director). Exceptional approvals for administrators as PIs will be made by the Vice Provost as appropriate.

7. Individuals appointed as Professor of the Practice, and those with modifiers of Emeritus, Adjunct or Visiting.

Questions concerning the foregoing guidelines may be addressed to Dr. Phil Kosch, Special Assistant to the Provost (617-636-3804 or philip.kosch@tufts.edu). The Vice Provost has assigned Dr. Kosch the responsibility for ensuring compliance with these guidelines.  

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