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RES-011: Investigator Eligibility Requirements and Responsibilities Related to Sponsored Programs

Date: 09/07/2021 Status: Final
Last Revised: 04/21/2022
Policy Type: University
Oversight Executive: Vice President for Research
Applies To:

Academic Division and College at Wise.

Reason for Policy:

This policy establishes institutional eligibility requirements and ongoing responsibilities of individuals holding senior/key roles on sponsored programs awarded to The Rector and Visitors of the University of Virginia and administered by the Office of Sponsored Programs. These requirements are necessary to meet the University’s obligations to sponsors and to facilitate compliance with award terms and conditions.

Definition of Terms in Statement:
  • Investigator:The project director or principal investigator and any other person, regardless of title or position: (1) who is responsible for the design, conduct, or reporting of research or proposed research, which may include, for example, senior research staff, collaborators, or consultants; and (2) whose research is supported by extramural funding (not internal funds or gifts).
  • Principal Investigator (PI):The individual(s) designated by the applicant organization/recipient to have the appropriate level of authority and responsibility to direct the project or program to be supported by the award. The applicant organization may designate multiple individuals as program directors/principal investigators (PD/PIs) who share the authority and responsibility for leading and directing the project, intellectually and logistically.
  • Sponsored Program:Any externally funded research, public service, or scholarly activity (including hosting or attending conferences) at the University that has a defined scope of work often including a set of specific programmatic objectives and/or deliverables, and line-item-based budget, providing the basis for sponsor expectations and awardee accountability (i.e., a reciprocal transfer of something of value). Sponsored programs are funded through agreements that usually include terms and conditions for the disposition of tangible properties and outcomes (e.g., equipment, records, specified technical reports, theses, or dissertations) or intangible properties and outcomes (e.g., rights in data, copyrights, and inventions). Note: The terms sponsored program, sponsored project, and/or sponsored activity are often used interchangeably.
Policy Statement:

As the recipient of sponsored programs awarded to support the activities of its faculty, the University is responsible for establishing, administering, and monitoring processes and procedures to meet its obligations to the sponsors and to comply with all applicable requirements. The type of research (or other supported activities), funding source, performance location, materials and methods, and other factors will determine the full range of requirements applicable to a sponsored program. In order to fulfill these obligations, the University has designated specific roles and responsibilities related to the oversight of sponsored programs.

Investigators are individuals who play a significant role in the design, conduct, or reporting of research and share in the associated responsibilities such as adherence to research integrity principles, professional standards and norms, institutional policies, and compliance with applicable regulatory requirements (e.g., national/federal, state, indigenous/tribal, locality, and sponsor).

A Principal Investigator (PI) is an investigator designated by the University to direct the activities supported by a sponsored program. The PI is responsible on behalf of the University for the sound technical, fiscal, and administrative management of the project or program in accordance with both University and sponsor requirements. Throughout this policy the term PI includes program directors and co-principal investigators.

  1. PI Eligibility:
    Only elected members of the faculty may submit sponsored program proposals. Elected members of the faculty include:

    • Professors
    • Associate Professors
    • Assistant Professors
    • Acting Assistant Professors
    • Emeritus Faculty

    While any elected member of the faculty is eligible to submit proposals, they may only serve as a PI on a sponsored program if, at the time the award is established, they have a paid appointment at UVA which is at least commensurate with the duration and level of time/effort they are expected to commit to the sponsored program.

    Deans, whether or not elected members of the faculty, are eligible to serve as a PI on a sponsored program proposal or award.

  2. Exceptions to PI Eligibility Requirements:
    Pre-doctoral students and post-doctoral trainees (i.e., research associates and fellows) may, when required by the sponsor or program guidelines, serve as PI on sponsored program proposals for mentored fellowships. The elected member of the faculty serving as the mentor will be the named PI in the University’s financial system and is responsible to the University for the technical and fiscal oversight of the project. Other exceptions to the PI Eligibility Requirements, above, will be considered by the Executive Director, Office of Sponsored Programs, provided the individual meets all the following criteria. The individual has:

    • An employee relationship with the University at the time of the award (i.e., it is expected that the individual would be receiving pay from the University at that time) at least commensurate with the duration and level of time/effort they are expected to commit to the sponsored program(s).
    • Received a written guarantee of space and administrative support by the appropriate unit leader (e.g., department chair, associate dean, or director).
    • The endorsement of the appropriate unit leader (e.g., department chair, associate dean, or director) and executive (e.g., dean or vice president).

    A request for an exception to the PI Eligibility Requirements, above, must:

    • Address the specific need for making the exception (e.g., sponsor requirement).
    • Explain how allowing the person to serve as a PI will further the University mission, institutional priorities, and career development of the individual.
    • Document the individual’s relationship with the University, their appointment, any space commitments, administrative support commitments.
    • Specify the requested length of time for the individual to serve as a PI (e.g., one-time request for a specific proposal or a set duration) which may not exceed the duration of the individual’s appointment.

    Incomplete requests will not be considered.

    Denial of an exception request may be appealed to the Vice President for Research who will make the final determination regarding PI eligibility.

  3. Ongoing Eligibility of PIs:
    Except for pre-doctoral students and post-doctoral trainees on mentored fellowships, individuals must maintain an active paid appointment at UVA that is at least commensurate with the duration and level of time/effort committed to active sponsored programs on which they are a PI (e.g., senior/key personnel). Faculty appointments are made by, and once accepted, may only be changed by the school/department.

    Except for pre-doctoral students and post-doctoral trainees on mentored fellowships, individuals without a paid appointment at UVA may not serve as a PI on a UVA sponsored program. If a PI’s paid appointment at UVA is ending (e.g., retirement or taking a position elsewhere), they must work with their unit (i.e., department, division, school, or institute, as appropriate) research administrators to determine the best approach to enable an individuals’ ongoing participation on a sponsor program (e.g., release the award or subcontract to the individual’s new institution; or work with the sponsor and OSP to designate a new PI and make the individual a paid consultant or unpaid advisor).

    Extended periods of full-time or part-time leave, paid or unpaid, by PIs must be reported to unit research administrators who will conduct an evaluation to determine if the nature, timing, and duration of the leave necessitates changes to committed effort, research performance timelines, or personnel on sponsored programs. Unit research administrators will work with the Office of Sponsored Programs to request approvals from research sponsors when required. Note: Investigators are advised to consult school research leaders or the Office of Sponsored Programs regarding what constitutes an extended period of leave that needs to be reported.

  4. Responsibilities:
    The Vice President for Research is responsible for:

    • Approving/Denying requests to allow spending on sponsored programs when a PI is ineligible and/or when any named Investigator is not current on required disclosures and/or training.
    • Hearing appeals of exception requests to PI eligibility requirements that have been denied.

    The Executive Director, Office of Sponsored Programs, is responsible for:

    • Approving/Denying requests for Exceptions to PI Eligibility Requirements.
    • Approving/Denying requests for temporary extension of disclosure and/or training completion requirements to facilitate timely proposal submission.

    The Office of Sponsored Programs is responsible for:

    • Enabling access to appropriate systems (e.g., proposal development, sponsor reporting, and financial administration) for individuals meeting eligibility requirements to be a principal investigator.
    • Developing procedures to confirm PI and Investigator eligibility, disclosure status, and training completion at appropriate points in the sponsored program lifecycle (i.e., from proposal to award closeout).
    • Coordinating with compliance and training program administrators to maintain a list of PIs and investigators on proposals and active sponsored programs.
    • When needed, requesting approval from sponsors for modification to active sponsored programs.

    Principal Investigators are responsible for technical, fiscal, and administrative oversight of sponsored programs including, but not limited to, the following:

    • Fostering ethical conduct, including by upholding research and professional integrity principles.
    • Establishing a safe and respectful research environment that that complies with all applicable University policies, including those policies prohibiting discrimination, harassment, retaliation, and other forms of interpersonal violence, and provides the opportunity for all members of the research team to thrive and succeed.
    • Implementing procedures to safeguard research data in compliance with sponsor requirements as well as applicable University policies, state and federal laws and regulations.
    • Providing general oversight of expenditures to confirm they are for the performance of the sponsored program, do not exceed approved budgets, and are in accordance with sponsor requirements as well as University policies and procedures, including those related to reporting/certification of payroll charges and/or effort expended.
    • Being knowledgeable of sponsor approval requirements regarding personnel, budgetary and programmatic changes to sponsored programs. Submitting and receiving prior approvals when required, e.g., budget reallocations, significant reductions in effort by or changes to PI(s), restricted expenditures such as equipment and travel, or timeline extensions.
    • Submitting accurate and complete technical reports and other non-fiscal reports to the sponsor on a timely basis.
    • Notifying and working with unit research administrators and relevant compliance offices prior to any extended period of leave (full-time or part-time) or change in physical location (e.g., absence from Grounds) that might impact responsibilities for ongoing research activities, including those related to compliance oversight and/or reporting (e.g., human subjects, animal subjects, biosafety, or export controls).

    Investigators are responsible for:

    • Maintaining current and accurate disclosures with the Office of Vice President for Research (OVPR) (e.g., significant financial interests) and Provost’s Office (e.g., external activities and appointments).
    • Completing initial and/or refresher training as required by the OVPR (e.g., research conflicts of interest, foreign influence, and research data security).

    Unit research administrators (e.g., individuals or research administration offices in a division, department, school, or institute) are responsible for:

    • Notifying and coordinating with the Office of Sponsored Programs to obtain any necessary approvals from research sponsors prior to implementing or authorizing changes to sponsored programs or UVA systems (e.g., research administration or financial systems).

    All individuals involved in research or research administration, regardless of role, are responsible for:

    • Reporting suspected non-compliance with University policies, sponsor requirements, or applicable laws/regulations to the OVPR or other appropriate University office or official.
  5. Compliance with Policy:
    Failure to comply with the terms of this policy may result in disciplinary action up to and including termination or expulsion in accordance with relevant University policies.

    The Office of Sponsored Programs will not submit a proposal if any PI is ineligible or if any named investigator (e.g., PI or senior/key personnel) is not current on required disclosures if doing so would violate sponsor requirements. However, spending on sponsored programs will not be permitted if any PI is ineligible or if any named Investigator is not current on required disclosures and/or training.

    An Investigator on a sponsored program who becomes ineligible under the provisions of this policy, or for any other reason, may have their access to sponsored program funds revoked or denied. In some instances, non-compliance may be reported to the research sponsor.

    Questions about this policy should be directed to the Office of Sponsored Programs.


NSF Harassment Protocol – While initially created to address NSF requirements, the University interprets this protocol to apply to all sponsored programs.

Major Category:
Research Administration
Next Scheduled Review:
Approved By, Date:
Policy Review Committee, 09/07/2021
Revision History:
Added pre-doctoral students/post-doctoral trainees to Section 2 4/21/22; Added VPR responsibilities, modified Compliance section 2/18/22.
Supersedes (previous policy):

Elements from Policy VIII.A.1, Grants and Contracts – Definition, Solicitation, Clearance and Acceptance; Procedure 8-8, Request for an Individual Not Meeting Policy Criteria to Serve as a Principal Investigator; and the PI responsibility statement from RES-009, Compliance with Sponsor Requirements.