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Definitions

"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

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 (unless required by the research sponsor, such as the U.S. Department of Energy). 

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 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.

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: 4/20/22