Policy on Principal Investigator (PI) Status

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Definitions

A principal investigator (PI) has full responsibility for the oversight of a sponsored project, including the design, development and implementation of the technical plan; as well as all administrative aspects, and financial and non- financial compliance aspects of the project. The PI is fully responsible for the academic quality of the project and for ensuring compliance with the terms, conditions, and policies of the sponsor and the university.

Multiple PI and co-PI: Some agencies allow for multiple principal investigators who share fully in both leading the scholarly activities and in the responsibility for all compliance issues connected with the project. Multiple PI is an NIH-specific designation. Co-PIs are subject to the same criteria and requirements as PIs under this policy. Co-PI is relevant as a designation on a grant application whenever allowed by the sponsor and can have varying definitions depending on the sponsor. The co-PI is a member of the research team who plays a major role in one or more aspects of the project (e.g., conceptual design of the technical aspects of the project, management of the implementation and administration of the project). Moreover, subject to approval by the funding agency, a co-PI may have to step in and assume the full responsibility of the project in the absence of the PI provided that (a) the person is automatically eligible for or can be granted PI status under this policy and (b) whenever they are empowered by the PI, or the relevant dean, vice president for research, or provost.

General Principles and Guidelines

• The PI designation involves two distinct functions: (i) an academic function of assuming the responsibility for the intellectual content of a grant, and the ability to oversee the design, development and implementation of the research project and (ii) a regulatory function of assuming responsibility for financial and non-financial compliance with the regulatory requirements of both the sponsor and the institution in the course of the research connected with the grant.
• From an institutional perspective regulatory oversight involves assuming the responsibility for (i) the grant’s budget, (ii) ensuring compliance with University protocols (e.g., IBC, IRB, IACUC, RSC, Laser Safety, Lab Safety – nonbiological), and (iii) ensuring the integrity and security of the research and data.
• Eligibility for Boston University PI status implies that the PI designation is allowed by the sponsor for that particular position/title and that the investigator takes responsibility for both academic and regulatory functions connected with the research project.
• Just as in the case of externally funded projects, all research carried out at Boston University, whether funded by the institution or unfunded, requires full academic and regulatory oversight by the Principal Investigator.
• Depending on position, title and rank, university personnel may (a) be automatically eligible for PI Status, (b) be ineligible for PI status, or (c) be eligible for PI status only after approval by the appropriate university official(s). As outlined in the body of this document, exceptions to the policy will only be made under very special circumstances and will require filling out the Request for Principal Investigator (PI) Status form. The following procedures determine if and under what conditions the university will allow a particular individual to be designated as PI on a grant, as defined by this policy.

Principal Investigator Status

PI Status At-a-Glance

(a) Automatic Full PI Privileges

Unmodified faculty positions

Except as noted below in relation to instructor positions, faculty who serve 50% or more time in unmodified standard faculty positions defined in Section A of “Classification of Ranks and Titles” in the faculty handbook¹ have automatic “PI – rights,” i.e., they can represent the university as PIs on grant applications and are eligible to serve as PIs on university protocols² without additional institutional approvals. Those in an unmodified Instructor position on the Medical Campus do have automatic PI privileges, while those in an Instructor position and all its modified forms on the Charles River and Fenway Campuses do not have automatic full PI privileges.

Modified faculty positions

Faculty who serve 50% or more time in the following positions defined in Section B of “Classification of Ranks and Titles” in the faculty handbook have automatic PI privileges:

• University Professor
• Clinical Assistant Professor, Associate Professor and Professor
• Professor of the Practice
• Research Assistant Professor, Associate Professor and Professor

Undergraduate students, graduate students, and postdoctoral scholars

Students and postdoctoral scholars have automatic PI privileges to apply for career advancement fellowships that are only open to trainees.

(b) No PI Privileges

(i) Visitors (in all designations), Adjunct faculty, Instructors on the CRC, and short-term (less than two years) employees cannot serve as the PI on grants submitted through Boston University and are also not eligible for PI Status on internal protocols.

(ii) Undergraduate and graduate students cannot serve as PIs on research grants and are not eligible for PI Status on internal protocols. When funded or unfunded projects that involve undergraduate or graduate students require internal regulatory approvals, the direct supervisor (the undergraduate teacher/advisor, doctoral mentor, or staff supervisor) assumes the PI responsibility for all internal protocols.

(iii) Industrial partners, who are eligible to use university facilities through contractual arrangements with the university, are not eligible for PI status on either proposals submitted through Boston University or on internal protocols.³

(c) PI Privileges with Approval

University employees and students who are not eligible for automatic PI status may apply for PI status for a specific project or for a five-year period. Individuals in the positions identified below may apply for PI status using the process outlined in the application process set out below so long as:

• The applicant is a paid, full-time employee, and the employment relationship with the Department or Center/Institute is expected to continue for the lifetime of the project.
• The applicant will be involved in the sponsored project in a significant manner. Primary responsibility for the academic and regulatory functions may not be delegated explicitly or implicitly to individuals who do not qualify, and have not been approved, to serve as PI.
• There will be sufficient capital resources to undertake the project, including equipment and space, and/or award funds to replace these and other departmental expenditures, including compensation for laboratory and support personnel, such as technicians and administrative staff.
• For each graduate student participating in the project, a qualified faculty member has been identified to assure that the student’s research program and the education derived from it are consistent with the degree for which the student is a candidate.

(i) Faculty who serve less than 50% time in positions with “automatic PI-rights” as defined in (a) may assume the role of PI on a Boston University grant provided that they are not a permanent employee (50% time or more) of and/or benefits from full PI rights at another academic institution, company, or organization.

(ii) Retired or emeriti faculty who are approved for an “extension of service,” which must be reviewed annually by the Provost or a Provost’s designee.

(iii) Faculty whose appointment start date is in the future may seek approval to apply for proposals through BU provided the project period start date is not prior to the appointment start date and the appointment has been approved by the Provost. In addition, an award cannot be accepted until the member’s appointment has begun.

(iv) Faculty who serve 50% or more time in the position of Associate Professors of the Practice, as defined in Section B of “Classification of Ranks and Titles” in the faculty handbook.

(v) Faculty who have appointment as Lecturers, as defined in Section C of “Classification of Ranks and Titles” in the faculty handbook, solely for project- specific PI status.

(vi) Research Scholars and Senior Research Scholars throughout the University, and Staff Scientists on the Medical Campus.

(vii) Non-research administrative staff may apply for PI status for:

(a) Facilities grants, construction grants, administrative grants, or other infrastructure grants with the approval of the relevant Provost (for a campus-centric project) or of the Vice President for Research (for university-wide projects).

(b) Research grants only if the proposed research meets a programmatic need of the University and is well-aligned with the individual’s job responsibilities. Meeting a programmatic need means addressing an area of investigation that is endorsed by the sponsoring school/college leadership and/or University-wide Leadership. Research that may be important and for which outside funding is available will not be judged as meeting the programmatic need criterion unless it facilitates the ongoing objectives of the University in an identifiable and direct way.

(viii) Postdoctoral scholars provided that the award is small in scope (less than $250,000 total direct costs) and does not require direct supervision of research personnel or student progress.

Application for PI Status

The home department or, for University-wide centers and institutes, the center or institute director, may submit an application for PI status for any individual in the positions described in the section on PI status with approval above. The application must include:

• The completed PI status application, signed by the department chair or center director; and
• A letter of recommendation that addresses:
  • How the proposed research or project is congruent with the interest of the department, center or institute;
  • The qualifications of the applicant relevant to competing for external funding with a reasonable possibility of success;
  • The candidate’s demonstrated ability to carry out the responsibilities of principal investigator, including meeting stated programmatic objectives of projects and administrative management of projects (financial and personnel); and
  • In the event the applicant is a postdoctoral scholar, the mentoring plan to ensure that the postdoc has appropriate training to meet the obligations of a PI, and a plan for reappointment (including funding) if the applicant’s tenure is scheduled to end prior to the end date of the proposed project.

In order to ensure due consideration, all applications for PI status must be submitted to the Associate Provost for Research or their designee at least one month prior to submitting a Proposal Summary Form for the proposed project. In the event a designee approves an application for PI status, the application and approval must be provided to the Associate Provost for Research.

¹Full time appointments (100% time) correspond to nine months on the CRC and Fenway Campus and 12 months on the Medical Campus.

²In the context of this policy “automatic privileges” implies that for these members of the faculty, the PI privilege is built into their initial appointment, and as long as there is no change in status this privilege requires no additional approvals. However, all proposals, irrespective of the level of PI privileges of the investigator(s), must be processed through Sponsored Programs and must comply with all institutional policies and procedures governing the submission and management of grants.

³Research carried out in university facilities by such outside agents must involve a genuine collaboration with a faculty member (as defined in (a)) who is both actively involved in the research and takes responsibility for all regulatory aspects by assuming the role of PI on internal university protocols relevant to the project. Such projects can be funded through a joint grant on which the Boston University faculty member takes full PI responsibility or through a Sponsored Research Agreement (SRA) to a (full-PI-privileges) faculty member’s laboratory.

Effective Date

The Policy on Principal Investigator Status takes effect immediately.

History

The Policy on Principal Investigator Status was drafted by the University Council Committee on Research and Scholarly Activity and approved by the University Council on 5/9/23.