April 24, 1992

Guidelines

Principal and Co-Principal Investigators:

Defining Roles, Rights, Responsibilities and Obligations

The Issues

The majority of applications for research grants and contracts are submitted by individual members of the University community and do not designate any other persons as Co-PIs. In such cases, if the application is favorably regarded by a funding source, the individual in question becomes the Principal Investigator and has the full obligations and rights as described below. However, in a minority of applications, several persons are listed as investigators, with one person being shown as "Principal Investigator" (or PIs) and the others usually as "Co-Principal Investigators" (or Co-PIs) and sometimes as "Co-Investigators". (In this document references to "Co-PI" are to be understood as applying equally to Co-Investigator.)

In the overwhelming majority of cases of joint applications, the parties involved implicitly or explicitly have shared understandings concerning their roles, rights, and responsibilities. Furthermore, if the application is successful, in an even larger majority of the cases, such shared understandings apparently successfully guide their collaboration and conflicts do not arise.

Nevertheless, in a small proportion of cases, disagreements have arisen among groups of investigators concerning what are the rights and responsibilities of PIs and Co-PIs. The disagreements have involved a variety of issues, including who has the right to authorize expenditures from research funds, who can exercise authority over research staff members, over equitable division of research trust funds returned to investigators, over intellectual property rights, as well as responsibilities to undertake research tasks. These disagreements have proved difficult to resolve because the rights and responsibilities of the parties involved are not defined clearly either in University documents or in written ad hoc agreements among the parties.

These guidelines have been written to define and clarify the roles of PIs and Co-PIs and to provide a mechanism to make explicit whatever understandings the parties involved may have concerning their specific roles in their joint projects. We recognize that styles of joint research activity vary widely across disciplines and individuals. These guidelines do not attempt to reduce this variability. Their main intent is to assure that all parties adopt a set of definitions that are acceptable to all and are also in compliance with relevant University regulations and guidelines.

Eligibility

Current University regulations state that all tenured and tenure track faculty may propose themselves as PIs and that other faculty may serve in that capacity with the endorsement of Department governance and relevant Deans. We propose to clarify that policy as follows:

Who Can be a Pl?

Persons holding the following positions may be designated as PIs in applications for outside research funding:

1. All tenured and tenure-track Assistant, Associate and Full Professors

2. All persons holding appointments as Research Assistant Professor, Research Associate Professor and Research Professor.

3. All persons holding Adjunct, Visiting, or other faculty positions, not included under 1 or 2 above, with the approval of the appropriate governance bodies of a Department and, also, the approval of the Dean of the relevant School or College.

4. All Post-Doctoral fellows with the approval of the appropriate governance bodies of a Department and, also, the approval of the Dean of the relevant School or College.

5. All professional staff who are not also students with the approval of the appropriate governance bodies of a Department and, also, the approval of the Dean of the relevant School or College.

Note that neither undergraduate or graduate students may be designated as PIs.

It is also to be understood that the right to submit proposals for outside funding is conditional upon the proposal being in compliance with relevant federal, state, and university regulations concerning the handling of hazardous substances, the treatment of human subjects, space availability, fiscal issues, etc.

Who can be a Co-PI?

Persons eligible for designation as PI are also eligible to be designated as Co-PIs. No undergraduate or graduate students may be designated as Co-PIs. Persons who are located at other universities and who do not hold appointments in eligible categories at UMass may not be designated as Co-PIs. Relations with collaborators at other universities, research institutes or corporations should be handled through subcontracts to the institutions involved.

These guidelines do not replace any existing restrictions placed by University regulations on applications for outside funding of research.

Responsibilities

Because most outside funding sources require that some specific individual be designated as PI, all research applications must designate some one person (and only one person) as PI. As PI, this person will be empowered to authorize expenditures of funds from funds when awarded. The PI is also entitled to receive RTF funds returned to investigators.

The responsibilities of a designated Pl include carrying out to the best of his or her ability, the activities specified in the proposal and in the grant or contract instruments. The PI also undertakes to observe relevant federal and state statutes as well as University regulations that govern fiscal accountability, the protection of human subjects, the use of animals in the research, the handling of toxic materials, and other relevant issues.

The responsibilities of PI may be shared with one or more Co-PIs. For example, several .persons may be empowered to authorize expenditures, or may divide among themselves the research tasks specified in the proposal or grant or contract instruments. The arrangements among PIs and Co-Pls may vary all the way from equality in powers and responsibilities to quite delimited spheres of autonomy.

The University does not require any specific set of arrangements concerning the division of responsibilities among PIs and Co-PIs . However, these guidelines require that the division of responsibilities among PIs and Co-PIs be made explicit and incorporated in a "Memorandum of Understanding.

The "Memorandum of Understanding" (MOU):

A "Memorandum of Understanding" (MOU) is required to be filed as part of the required "agreement with terms" for each and every funded grant or contract proposal which designates one or more Co-PIs and is to be signed by each and every PI and Co-PI, thereby signifying their agreement to the terms laid out in the MOU. OGCA will not authorize the establishment of any accounts for a funded grant or contract until a MOU has been filed. Each MOU should describe what are the mutual understandings among the signatories concerning the following issues:

1. Who may authorize expenditures from grant or contract funds.

2. Responsibilities for carrying out major tasks specified in the proposal and granting instruments, including the preparation of reports required by grants or contracts (with the exception of financial reports to be prepared by Accounting).

3. Division of RTF returned to investigators.

4. Rules of succession in the event of the resignation or incapacity of a signatory.

Of course, the terms of any MOU cannot contravene or replace existing statutory or University regulations.

It is presumed that intellectual property rights, especially authorship of papers and publications or other intellectual products will be governed by the terms of the Policy Statement on Joint Authorship, as approved by the Graduate Council, 2 April 1990, and signatories to a MOU will be required to affirm that they have read and understand the Policy Statement. Any deviations from the Policy Statement should be noted in the MOU.

It is not intended that a MOU be necessarily a lengthy document. A MOU may simply state that all of the responsibility for handling the above issues resides in the PI or may simply state that all of the responsibilities and rights are shared equally. In most cases, a MOU can be accomplished by filling out a standard questionnaire. However, we recognize that in some cases a MOU may be a complex document.

Dispute Handling:

Although it is the intent of these guidelines to avoid disputes among research collaborators, it is recognized that some disputes nevertheless will occur. Disputes among collaborators that cannot be handled by the parties among themselves should be referred to the Dean of the school of college in which the PI holds an appointment. In the case that a Dean is involved as a PI or Co-PI, or considers her/him, self to have a conflict of interest, the dispute will be forwarded to the Vice Chancellor for Research.

In the event that the relevant Dean or the Vice Chancellor for Research is unable to bring the dispute to settlement, the parties may resort to the complaint procedures designated for the handling of Research Misconduct issues.

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