University Policy Number 4012
Related Law & Policy:
I. PURPOSE AND SCOPE
This policy addresses the qualifications, roles, and responsibilities of a Principal Investigator (PI) at George Mason University. On September 24, 2007, the Office of Science and Technology Policy in the Executive Office of the President expanded Federal guidance on this subject in a notice entitled “Agency Recognition of Multiple Principal Investigators on Federally Funded Research Projects.” The notice requires that all Federal research agencies recognize multiple PIs on research projects (grants and contracts) if proposing institutions wish to adopt this approach to conducting the research. The notice describes the central roles and responsibilities of a Principal Investigator and requires that each funding agency post its plan to implement the policy beginning in 2008.
This university policy reflects current Federal policy. In addition, it consolidates and clarifies current guidance on the qualifications, roles, and responsibilities of Principal Investigators at the university.
II. POLICY STATEMENT
In order to serve as a Principal Investigator for a sponsored research project or for a IRB, IACUC, IBC, or RSC protocol at the university, an individual must hold one of the following types of appointments: (1) a tenured appointment, (2) a tenure-track appointment, (3) a full-time, fixed-term appointment as a member of the instructional, research, or clinical faculty, or (4) an administrative or professional faculty appointment. There are two exceptions. First, an adjunct or affiliate member of the faculty may serve as a Principal Investigator with the approval of his or her dean or institute director. In approving an adjunct or affiliate faculty member as a PI, the dean or director assumes responsibility for the execution of the project financially and in terms of the work of the project. Second, a member of the faculty at a collaborating institution may serve as a Principal Investigator if a member of the George Mason University faculty who meets the requirements of this policy also serves as a Principal Investigator on the project. Major contributors to a project who are not Principal Investigators are referred to as “Co-Investigators.”
In some circumstances, the designation of the Principal Investigator may be made at the time of award. A prospective member of the faculty may submit a proposal for funding if he or she has received an offer of employment from the university but may serve as a Principal Investigator only if he or she meets the requirements of this policy when the project is funded. Similarly, a postdoctoral fellow at the university may submit a proposal for funding but may serve as a Principal Investigator only if he or she meets the requirements of this policy when the project is funded.
A Principal Investigator is an individual designated by the university as having an appropriate level of authority and responsibility for the proper conduct of the research, including the appropriate use of funds and administrative requirements such as the submission of scientific progress reports to the funding agency. If the university designates multiple Principal Investigators for a project, they share the authority and responsibility for leading and directing the research, intellectually and logistically. Neither the agency nor the university attributes any difference in scientific stature to faculty members who serve as multiple PI’s.
- Contact Principal Investigator
If the university designates multiple Principal Investigators for a project, it designates one of the multiple PI’s as the Contact Principal Investigator. A Contact PI is the person to whom agency program officials direct all communications related to scientific, technical, and budgetary aspects of the project. Individual agencies may refer to the person who is responsible for project-related communications by various terms, such as Contact PI, Coordinating PI, or Project Coordinator.
- Project Administration
A Principal Investigator has a number of specific responsibilities relating to the administration of the project. Members of the university community may obtain advice on these responsibilities and assistance in discharging them from the university’s Office of Sponsored Programs (OSP, https://osp.gmu.edu/), Office of Research Integrity & Assurance (IRB, IACUC), or Environmental Health & Safety Office (IBC, RSC).
- Level of Effort
A Principal Investigator is responsible for ensuring that each faculty member and senior researcher identified in the project proposal contributes some level of effort, paid or unpaid by the sponsor, to the project unless the project is for equipment and instrumentation, a doctoral dissertation, or student augmentation.
The Vice President for Research and Economic Development is responsible for the administration of this policy. The Office of Sponsored Programs has administrative responsibility for all externally-sponsored projects at the university. The Office of Research Integrity & Assurance has administrative responsibility for all projects involving human subjects and vertebrate animals. The Environmental Health & Safety Office has administrative responsibility for all safety committees and projects reviewed by these committees.
IV. EFFECTIVE DATE AND REVIEW
This policy is effective upon approval by the Provost and the Associate Vice President. The policy will be reviewed and, if necessary, revised every five years or sooner if circumstances require. Any revision will take effect at the beginning of the first university fiscal year following its approval unless the revision specifies a different date.
In approving a part-time faculty member as a Contact Principal Investigator, the dean or director assumes responsibility for the execution of the project financially and in terms of the work of the project.
See OMB Memorandum for the Heads of Executive Departments and Establishments clarifying OMB Circular A-21, “Cost Principles for Educational Institutions,” Jan. 5, 2001. In addition to requirements relating to a minimum level of effort, Federal guidelines contain limitations on the maximum level of effort that may be charged to funded projects. Salaries for positions that include responsibilities for competitive proposal writing and regular administrative duties may not be charged 100% to sponsored awards.
Associate Vice President/Controller
Peter N. Stearns
Date: September 24, 2012