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Definitions 

Investigator (according to University Policy 1-006: Individual Financial Conflicts of Interest) means an individual, regardless of whether or not an Employee, who is the project director or the Principal Investigator 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.

Senior/key personnel (according to 42 CFR Subpart F: Promoting Objectivity in Researchmeans the PD/PI (Project Director/Principal Investigator) and any other person identified as senior/key personnel by the Institution in the grant application, progress report, or any other report submitted to the PHS (Public Health Service) by the Institution under this subpart.

Process for Identifying Investigators

Principal Investigators are responsible for identifying members of the research team who qualify as Investigators or Senior/Key Personnel. PIs should provide a list of all Investigators and Senior/Key Personnel in the University's eAward system in the "Award Management - Change of Personnel" section. Personnel providing only technical support outside of the design, conduct, or reporting of the research do not need to be listed in eAward. 

Principal Investigators should evaluate the roles of students, postdoctorals, consultants, collaborators, research affiliates, etc. working on the research project. Any individual meeting the definition of Investigator or Senior/Key Personnel should be listed in eAward. If a PI is unsure if an indivdual meets those definitions, the PI should consult the COI Office.

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 always be listed as an Investigator/Senior/Key Personnel in eAward.

Subrecipients - For all subawards issued to entities outside the University of Utah, subrecipients are required to comply with a PHS-compliant COI policy. If the institution/entity receiving a subaward from the University of Utah does not have a PHS-compliant policy, the subrecipient PI should contact the University of Utah's Office of Sponsored Projects and COI Office.

Research Affililates - If a University Research Affiliate (paid or unpaid) is responsible for the design, conduct, or reporting of the research, the Research Affiliate should be listed as an Investigator in eAward. A Research Affiliate who qualifies as an Investigator should be listed in eAward 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 in eAward.

SBIR/STTR Awards - Any individual who meets the definition of Investigator or Senior/Key Personnel conducting research at the University should be listed as an Investigator in eAward. This includes any individual who may also be conducting research for the Small Business Concern, or main recipient of the award. Additionally, if a graduate student/fellow or postdoctoral fellow qualifies as an Investigator on research conducted under the supervision of that individual's sponsor, the sponsor should be listed as an Investigator/Senior/Key Personnel in eAward.

Last Updated: 4/6/21