1310 Principal Investigator Eligibility Requirements on Sponsored Projects

Policy Sections

1310.1 Eligibility Requirements for Faculty as Principal Investigator

1310.2 Eligibility Requirements for Trainees as Principal Investigator

1310.3 Eligibility Requirements for Staff as Principal Investigator

1310.4 Proposal Approval Requirements

This document applies to all proposals submitted to external sponsors seeking monetary or non-monetary support of a sponsored project which, if awarded to Yale University will be governed by a contract, grant, cooperative agreement or other binding agreement.

This policy does not apply to consultant agreements or the procurement of goods or services from vendors.

As a condition of its acceptance of sponsored project awards from external sponsors, the University is obligated in its role as the recipient of the award to ensure that:

• only individuals meeting the eligibility requirements of this policy are listed as Principal Investigator, co- Principal Investigator, or program director on proposals;
• all proposals are reviewed, approved and submitted by an authorized individual acting on behalf of the University; and
• all proposals submitted meet the requirements of the sponsor.  If the sponsor’s requirements are less restrictive than the University’s policy, the University’s policy shall take precedence.

All individuals serving as a PI on a sponsored award must:

• complete the Patent Policy Acknowledgment and Agreement (“PPAA”) form;
• complete Sponsored Projects Administration Training for Yale Faculty;
• complete and submit an up-to-date Conflict of Interest (“COI”) Disclosure form; and
• complete and submit Form 1411 FR.01 Yale University/West Haven Veterans Administration Medical Center (“VA”) Joint Appointment Memorandum of Understanding, as applicable.

The purpose of this policy is to:

• establish criteria permitting individuals to fulfill the role of Principal Investigator, program director, or co- Principal Investigator on a sponsored project; and
• ensure that sponsored projects are conducted by those who have the requisite training, skill, commitment, and resources, as well as the appropriate relationship to the University.

Principal Investigator (or program director or co-principal investigator)

This individual is designated by the University and approved by the sponsor to direct a project funded by an external sponsor.  S/he is directly responsible and accountable to the University and sponsor for the proper programmatic, scientific, or technical conduct of the project, and its financial and day-to-day management.

The Principal Investigator is a critical member of the sponsored project team responsible for ensuring compliance with the financial and administrative aspects of the award.  The Principal Investigator works closely with appropriate administrators within the University to create and maintain necessary documentation, including both technical and administrative reports; prepare budget justifications; appropriately acknowledge external support of research findings in publications, announcements, news programs, and other media; and ensure compliance with other Federal and organizational requirements.  It is expected that the Principal Investigator will maintain contact with the appropriate sponsor representative with respect to the scientific aspects of the project and the business and administrative aspects of the award.

In order for a faculty member to be a Principal Investigator (co- Principal Investigator or program director), the individual must:

• be a full-time employee of the University;
• hold the academic rank of professor, associate professor, assistant professor, senior research scientist/scholar, research scientist/scholar, Senior Lector II, or Senior Lecturer II; and
• have the requisite training, skill, commitment, and expertise.

Exceptions to the above eligibility requirements require the approval of the Provost, or where appropriate, the Dean of self-support units.  Exceptions may be made for, but are not limited to: associate research scientists/scholars, lecturers, instructors, emeritus faculty¹, and other non-full-time appointments (Complete Form 1310 FR.04 Principal Investigator (“PI”) Status Request Form).

Trainees, whether or not they are employees (such as postdoctoral fellows/associates, students, interns, or residents), may apply for external fellowships and mentored career development awards only with the approval of a Yale faculty sponsor or mentor as indicated either on the application and/or the proposal transmittal form/Proposal Development (“PD”) record.

Exceptions to the above eligibility requirements require a completed Form 1310 FR.04 Principal Investigator (“PI”) Status Request Form, which includes the approval of the Provost, or where appropriate, the Dean of self-support units.

In order for a staff member to be a Principal Investigator (co- Principal Investigator or program director), the individual must:

• be a full-time employee of the University;
• demonstrate sufficient reason to be a Principal Investigator (co- Principal Investigator or program director); and
• seek approval from the Provost or Dean of self-support units to submit an application to an external sponsor. 

All applications for external sponsorship must indicate the approval of the appropriate Department Chair and either the Dean for self-support units or the Provost (as appropriate), indicating assurance to provide the resources (including space) necessary to carry out the project.

Chair, Dean, or Provost (as appropriate)

• Ensure that all proposal submissions contain an eligible individual as a Principal Investigator, co- Principal Investigator, or program director and the eligible individual(s) have adequate resources available to complete the proposed sponsored project successfully.
• Approve exceptions to this policy, when appropriate.

Departmental Business Office

• Ensures that all proposal submissions to the Office of Sponsored Projects (“OSP”) indicate eligible individuals as Principal Investigator, co- Principal Investigator, or program director.
• Receives the appropriate prior approvals for proposal submissions.
• Ensures that Principal Investigator has available effort to devote to the project.
• Ensures the individual has completed the following:
  
  • Patent Policy Acknowledgement and Agreement (“PPAA”) form;
  • Sponsored Projects Administration Training for Faculty;
  • Conflict of Interest Disclosure“ (“COI”) form; and
  • Form 1411 FR.01 Yale University/West Haven Veterans Administration Medical Center (“VA”) Joint Appointment Memorandum of Understanding, as applicable.

Office of Sponsored Projects (“OSP”)

• Approves all proposal submissions indicating eligible Principal Investigators, co- Principal Investigators, or program directors, ensuring that all eligibility approvals are in place.

¹ Note that emeritus faculty may request the title of Research Professor for the submission of Proposals (see Faculty Handbook Section XVII B 4).  Form 1310 FR.04 Principal Investigator (“PI”) Status Request Form is still required for each proposal submission.