Policy No: 2059 Responsible Office: Sponsored Projects Administration Last Review Date: 04/12/2022 Next Required Review: 04/12/2024
Sponsored projects are awarded in the name of the University of South Alabama. The Principal Investigator (PI) is the individual with primary responsibility for carrying out the sponsored project. The PI is legally accountable to USA and to the sponsoring agency for the proper execution of the project and proper expenditure of the sponsor’s funds.
This policy applies to Academic Affairs, Research and Economic Development and Medical Affairs, in addition to any other Divisions responsible for the assignment of Principal Investigators for proposals submitted in the name of the University of South Alabama (USA) and those named in other externally funded projects. The policy applies when USA is the direct award recipient and instances in which USA is a collaborator/sub awardee. The policy also includes pre-proposals which require authorized official approval and/or submission via a sponsor system.
Business Day: Normal operation hours for the USA and SPA, which exclude holidays, weekend days, or emergency closing. For purposes of this policy, a business day will be a full working day in advance of the sponsor deadline.
Business elements: Segments of a proposal including but not limited to budget, budget justification, cost share commitment, identification of required resources, biosketches, supporting documents for subrecipients, compliance documents, and FCOI documents.
Grant Administrator: The individual, usually resident within a unit, who has contact responsibility for proposals and their internal business process.
Proposal: A document prepared for submission to an external agency for funding consideration.
PI (Principal Investigator): The USA individual who is responsible for the overall project performance, including sponsored activity, financial oversight and compliance with sponsor and USA policies.
Sponsor: A federal agency, private entity, non-profit organization, institution or other external entity that provide funding or other support for supported activity.
Submission: Action taken by SPA to officially transmit the proposal to the external funding agency.
Unit: Department, College or other recognized USA area from which the proposal originates.
4. Policy Guidelines
The role of PI for a sponsored project may only be attained by eligible USA faculty, administration, or staff with primary responsibility for design, execution, and management of the project, who will be involved in the project in a significant manner, and who meet the conditions detailed within this policy.
5.1 The individual desiring to serve must meet any PI eligibility requirements specified by the sponsor. Tenured faculty, tenure-track faculty, and non-tenure track faculty members (including research faculty members) are eligible to serve as PI on a sponsored project. Authorizing officials confirm the eligibility of a PI when approving a proposal in USA’s Cayuse system.
5.2 A non-USA employee (e.g., student, postdoctoral appointee, adjunct or visiting faculty), or temporary employee is ineligible to serve as PI. However, a sponsor’s program guidelines may encourage or permit non-USA employees and temporary employees to apply as PI for a specified program. In this case the sponsor’s application form will indicate the non-USA or temporary employee as the PI and list a PI-eligible USA employee as an investigator. For internal USA purposes, the eligible USA PI would be shown as PI in Cayuse and would be responsible for supervising project activities of the non-USA or temporary employee investigator.
5.3 In cases where there are collaborations on a sponsored project and the designation of the PI is an issue, the Chair(s)/Dean(s) will have primary responsibility for the selection/designation of the PI. For SPA’s purposes, the concurrence of the Department Chair and College Dean concerning who will serve as PI is documented by electronically approving the role associated with proposals routing through USA’s Cayuse system.
5.4 USA staff or administrative employees (an employee without a faculty appointment) may serve as a PI on a sponsored project provided the employee meets the same requirements and obtains the same concurrences as those required of a faculty member. Depending upon the employee’s status within the specific USA unit, concurrence to serve as PI must come from the employee’s direct supervisor (Department Chair or equivalent) and the Unit/Division Director (Dean or equivalent.) Additionally, the approval of the Vice President for Research and Economic Development is required and should be obtained well in advance of any deadline for proposal submission.
5.5 For clinical trials, the PI is generally an MD. If the PI is not an MD, the individual may serve as PI with approval of the Dean of the College of Medicine, Nursing or Allied Health or Director of Mitchell Cancer Institute, as appropriate.
5.6 Faculty members who wish to continue research after retiring from USA may continue to serve as PI for the life of the funded project if approved by the chair and dean. The designation of PI will not be associated with employment and will terminate at the conclusion of the award term.
5.7 USA graduate and undergraduate students are not permitted to serve in the role as PI as they are not subject to the same accountability as faculty and staff. However, certain sponsors and programs treat students as a PI and will name them on the sponsor forms submitted for funding consideration. Under these circumstances, a PI of Record will be recognized as the faculty member who agrees to have oversight of and to be responsible for the project.
5.8 A newly hired faculty member prior to arrival on campus is able to serve as PI if the formal Letter of Appointment has been executed and accepted by the USA and if approved by the College Dean. The start date for the proposed project and the Letter of Appointment must concur.
The responsible parties for oversight and enforcement of this policy are:
Policy Oversight: Vice President for Office of Research and Economic Development.
Policy Enforcement: Executive Director, Sponsored Projects Administration.