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"Investigator" means an individual, regardless of whether or not an Employee, who is the project director, the principal investigator, or Senior/Key Personnel for a Research project, or any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of Research conducted in whole or in part under the auspices of the University, which may include, for example, visiting scientists, collaborators, consultants, or sub-award or subcontract recipients.

    1. For Research sponsored by the United States Department of Energy, or if required by a Research sponsor, “Investigator” also includes a person who participates in the design, conduct, or reporting of Research conducted in whole or in part under the auspices of the University

"Senior/Key Personnel" means the project director, principal investigator, and any other individual identified as Senior/Key Personnel by the University in the grant application, approved budget, progress report, or any other report submitted to the PHS or other federal sponsor.

Process for Identifying Investigators

The Principal Investigator ("PI") is responsible for identifying members of the research team who qualify as Investigators (including Senior/Key Personnel). The PI must provide a list of all Investigators the University's research application systems (ERICA, eAward, eProposal) for the project, so that COI review may occur. This list should be updated and confirmed periodically (for example, at the time of continuing review for an IRB application, when new subaward transactions are issued, and as needed when changes to personnel occur).  

The PI should evaluate the roles of students, postdoctorals, consultants, collaborators, research affiliates, etc. working on the research project. Any individual meeting the definition of Investigator should be included on the list of Investigators. If a PI is unsure if an indivdual meets those definitions, the PI may consult the COI Office. Individuals providing only technical support outside of the design, conduct, or reporting of the research do not need to be listed as Investigators (unless required by the research sponsor, such as the U.S. Department of Energy). 

Additional Considerations

Supervisors (Faculty Sponsors) of Graduate Students and Postdocs - If a graduate student/fellow or postdoctoral fellow qualifies as an Investigator on research conducted under the supervision of that individual's supervisor/faculty sponsor, the supervisor/faculty sponsor should also be listed as an Investigator.

Research Affililates - If a University Research Affiliate (paid or unpaid) is responsible for the design, conduct, or reporting of the research under the auspices of the University, the Research Affiliate should be listed as an Investigator. A Research Affiliate who qualifies as an Investigator should be listed even if the Research Affiliate is not employed by the University.

Authorship - Any individual listed as an author on a submitted manuscript describing research is considered an Investigator and should be included in the list of Investigators.

SBIR/STTR Awards - Any individual who meets the definition of Investigator conducting research under the auspices of the University should be listed as an Investigator. This includes any individual who may also be conducting research for the Small Business Concern, or main recipient of the award. 

External Subrecipients - For all subawards issued to entities outside the University of Utah, subrecipients are required to certify that they abide by a financial conflict of interest policy that is equivalent to the University's policy (1-006 and associated regulations). Subrecipients who cannot provide this certification are required to abide by the University of Utah's policy (1-006 and associated regulations), regardless of the primary funding source of the award, and in doing so they agree to follow the procedures for COI review to occur prior to the subaward being fully executed.

Last Updated: 11/15/22