Public Health Service/National Institute of Health
Based on the PHS/NIH definitions below, all individuals listed as “senior/key personnel” on a PHS funded proposal, award, or a project sponsored by an entity following PHS regulations are considered “Investigators.” Therefore, all senior/key personnel must submit financial disclosures (Form 800) and complete COI training as required by the PHS regulations.
Please note the definition of Investigator is broader than the definition of senior/key personnel so there may be investigators on the project who are not senior/key personnel.
Investigator means the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants.
The 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. "Zero percent" effort or "as needed" is not an acceptable level of involvement for senior/key personnel.
Principal Investigators should carefully consider how they classify the individuals involved in their study based on the PHS definitions, due to the different requirements and implications. The Principal Investigator is responsible for accurately classifying the individuals on their project based on their responsibilities, and collecting financial disclosures from all project participants that meet the definition of “Investigator.”
National Science Foundation
NSF Definitions of Categories of Personnel are based on titles not responsibilities in the funded project. However, the NSF COI Policy requires Principal Investigators/Project Directors identify individuals as Investigators based on their responsibilities on the project. All Investigators, which may include senior personnel and other personnel, are required to submit financial disclosures (Form 900).
The Principal Investigator is responsible for accurately classifying the individuals on their project based on their roles, and collecting financial disclosures from all project participants that meet the definition of “Investigator.”
Investigator means the principal investigator, co-principal investigators/co-project directors, and any other person at the organization who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by NSF.
· (co) Principal Investigator/Project Director (PI/PD)- Form 900 always required
· Faculty Associate (faculty member)
· Postdoctoral (Scholar, Fellow or Other Postdoctoral Position)
· Other Professional
· Graduate Student (research assistant)
· Undergraduate Student
· Persons working on project in a non-research capacity
For the NSF Definitions of Categories of Personnel, visit http://www.nsf.gov/pubs/policydocs/pappguide/nsf14001/gpg_2.jsp#IIex7.