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  5. Sponsor-Specific Guidance

Sponsor-Specific Guidance

All Investigators must comply with the University鈥檚 Policy on Conflicts of Interest in Research,
regardless of sponsor.

鈻�   United States Public Health Service (PHS)

NIH grant Policy Statement (GPS) defines senior/key personnel as: 鈥淭he PD/PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant.鈥�  For further details please reference ...

鈻�   US Department of Energy (DOE)

DOE defines Senior/key personnel as 鈥渢he PI; any other person who significantly influences the design, conduct, or reporting of a project funded under a DOE award; and any other person identified as senior/key personnel by the non-Federal entity in the application for financial assistance, approved budget, progress report, or any other report submitted to the DOE.鈥�

  • Applicability: DOE and all subordinate offices, agencies, and national laboratories
  • Policy:
  • Who must disclose: Principal Investigators, Co-Investigators, Key Persons, and others who meet the DOE definition
  • Effective date: December 20, 2021
鈻�   National Science Foundation (NSF)

NSF defines Senior Personnel as, 鈥渋ndividuals designated by the proposer/awardee organization and approved by NSF, who contribute in a substantive, meaningful way to the scientific development or execution of a research and development project proposed to be carried out with a research and development award鈥�.

  • Applicability: NSF and all subordinate offices and agencies
  • Policy:
  • Who must disclose: Principal Investigators, Co-Investigators and other personnel who meet the NSF definition. (NSF I-Corps external personnel may be required to certify through MIT)
  • Effective date: May 20, 2024
鈻�   National Aeronautics and Space Administration (NASA)

NASA defines a Principal Investigator (PI) as the individual whom an organization designates as having an appropriate level of authority and responsibility for the proper conduct of proposed work effort,  including the appropriate use of funds and administrative requirements such as the submission of progress reports to the agency. Every proposal shall identify a PI who is responsible for the quality and direction of the proposed work effort and for the proper use of awarded funds regardless of whether the PI receives support through the award. 

  • Applicability: NASA and all subordinate offices and agencies
  • Policy:
  • Who must disclose: Principal Investigators, Co-PIs, Key Persons, and others who meet the NASA definition
  • Effective date: December 1, 2023