The University of North Carolina at Wilmington (UNCW) pursues and accepts funding from sponsors for the conduct of research, instruction, and public service projects. Most proposals for such Sponsored Projects are submitted in the name of and by UNCW, and all resulting awards are likewise accepted in the name of UNCW by a university Authorized Organizational Representative (AOR).
Provost and Vice Chancellor for Academic Affairs
June 2024; Replaces 09.007 Principal Investigator Responsibilities for Sponsored Programs.
Sponsored Programs and Research Compliance
Background
The University of North Carolina at Wilmington (UNCW) pursues and accepts funding from sponsors for the conduct of research, instruction, and public service projects. Most proposals for such Sponsored Projects are submitted in the name of and by UNCW, and all resulting awards are likewise accepted in the name of UNCW by a university Authorized Organizational Representative (AOR). Principal Investigators, Co-Principal Investigators, and Project Directors are responsible for the preparation, conduct, and administration of sponsored projects. Thus, it is essential that qualified individuals are designated to serve in the role of Principal Investigator, Co-Principal Investigator, and Project Director in a manner consistent with the UNC Policy Manual and Code, Section 500 – Sponsored Programs, Research, and Intellectual Property and aligned with the UNCW’s policy on ethics.
Purpose
This policy defines the roles and responsibilities of the Principal Investigator, Co-Principal Investigator, Project Director, and Co-Investigator (also referred to collectively as investigators) on sponsored projects at UNCW and identifies who may serve in these roles.
Scope
This policy applies to all individuals seeking approval to serve as Principal Investigator, Co-Principal Investigator, Project Director, or Co-Investigator on a Sponsored Project.
Definitions
Capitalized Terms identified in this policy are defined as follows.
Authorized Organizational Representative (AOR): a university officer with institutional authority and responsibility for Sponsored Projects. At UNCW, AOR responsibilities are delegated from the Chancellor to the Chief Research Officer and to the Director and Assistant Director of Sponsored Programs and Research Compliance (SPARC).
Co-Investigator (Co-I): An individual involved with the principal investigator in the intellectual development or execution of a Sponsored Project or part of a Sponsored Project. A Co-Investigator typically devotes a specified percentage of time to the Sponsored Project and is considered senior or Key Personnel. The designation of a Co-Investigator, if applicable, does not affect the Principal Investigator's roles and responsibilities as specified in this policy statement. [Source: NIH Grants Policy Statement 2022]
Co-Principal Investigator (Co-PI): When multiple PIs share authority for leading and directing the Sponsored Project (including intellectual, logistical, and financial responsibility), they are designated as Co-Principal Investigators (Co-PIs). Each Co-PI is responsible and accountable for the proper conduct of the project, including the submission of all required reports. While in practice multiple Co-PIs may have differentiated roles or operational domains in the conduct of the project, the designation of multiple Co-PIs for a single project does not diminish the responsibility or the accountability on any individual PI. One of the multiple Co-PIs must be designated as the Contact Principal Investigator. See description of responsibilities in Section VII. [Consistent with NSF PAPPG17-1 Exhibit II-7]
Contact Principal Investigator: This is the PI or Co-PI of a Sponsored Project designated as the primary contact for project administration. Some sponsors may require the Contact PI to be identified as the Principal Investigator.
Key Personnel: Individuals who contribute in a substantive way to the intellectual development or execution of a project, whether or not they receive compensation from the grant supporting that project. Principal Investigators, Project Directors, Co-Principal Investigators, Co-Investigators are Key Personnel. Some agencies alternatively refer to Key Personnel as Senior Personnel. Key Personnel typically commit measurable effort to project, regardless of compensation. At UNCW, Key Personnel are subject to Conflicts of Interest and Commitment training and disclosure requirements. [Source: NIH Grants Policy Statement 2022]
OSPREY: The Online Sponsored Programs & Research Enterprise sYstem (OSPREY) is UNCW’s electronic research administration system. It includes modules to support multiple facets of research administration including proposal development, review and approval, a database to find funding (SPIN), and compliance modules for conflicts of interest and human subjects research (i.e., Institutional Review Board).
Principal Investigator (PI): An individual designated by the grantor and UNCW to direct a project or activity being supported by a Sponsored Project. A Principal Investigator is responsible for leading the preparation, conduct, and administration of a Sponsored Project. Some sponsors use the term Project Director as a synonym for Principal Investigator. See description of responsibilities in Section V.
Project Director: A title used by some sponsors that is a synonym for Principal Investigator. See description of responsibilities in Section V.
Sponsored Programs and Research Compliance (SPARC): The UNCW office that provides pre-award and post-award sponsored program administration and support, including assisting Principal Investigators, Co-Principal Investigators and Project Directors with identifying funding sources, assisting with proposal development, overseeing the responsible management of sponsored projects, and ensuring UNCW’s compliance with contract/grant fiscal and regulatory requirements and policies.
Sponsored Project: Exchange transaction, generally in the form of a grant, cooperative agreement, or contract, with a defined scope of work, specified budget, and specific deliverables, and typically subject to audit and compliance requirements. Usually these are initiated by a funding agency or sponsor through a program announcement or other type of solicitation. These include but are not limited to Sponsored Projects for research. All Sponsored Projects are routed for institutional review and approval through SPARC pre-award services and are managed for compliance financially by SPARC’s post-award services.
Capitalized terms not otherwise defined in this policy shall have the meaning ascribed to them in in the document entitled “Definitions for Research Administration” maintained by SPARC.
Responsibilities of Principal Investigators, Co-Principal Investigators, and Project Directors
The Principal Investigator (PI), Co-Principal Investigator (Co-PI), and/or Project Director (PD) have authority and responsibility for the intellectual, logistic, and financial leadership of a Sponsored Project. These roles have multiple responsibilities, including but not limited to the following:
Ultimately, the PI, Co-PI, and/or PD have a responsibility to the sponsor, any data provider, the department, the college or division, and UNCW to ensure that the requirements of the Sponsored Project are met and the policies of the university are followed.
Sponsored Projects are conducted as a function of the appropriate academic or administrative unit (department, college, or division). Financial management and responsibility of the Sponsored Project also rests with the appropriate academic or administrative unit.
Research and Innovation maintains a matrix of roles and responsibilities related to the post-award administration of Sponsored Projects.
Principal Investigator, Co-Principal Investigator, and Project Director Eligibility
Serving as a PI, Co-PI, and PD is a responsibility granted to UNCW personnel. Any person granted PI, Co-PI, and/or PD authority must accept all responsibilities associated with the application for and administration of awarded Sponsored Projects (Article V). Unless an exclusion or exception applies under Article IX, all PIs, Co-PIs, and PDs must meet one of the following eligibility criteria prior to being named to these roles.
Employees: Permanent, paid, full-time or part-time employees (non-student) of UNCW may serve as a PI, Co-PI or PD on Sponsored Programs. Employees must consult with their supervisor to ensure that Sponsored Program activity is acceptable for their position and effort.
Phased Retirement: UNCW faculty in phased retirement can serve as a PI, Co-PI, or Director, as applicable, on a Sponsored Project, with written permission of the applicable Department Chair or School Director and Dean, if the funded Sponsored Project is included in the duties listed in the 50% work plan required for moving to phased retirement status. UNCW faculty members on phased retirement whose retirement plans are with the State of North Carolina (TSERS) cannot earn additional income.
Emerit Status: UNCW Emerit faculty may serve as a PI, Co-PI, or PD with written permission of the Department Chair or School Director and the appropriate Dean/Director/Vice Chancellor, and the Associate Provost for Research and Innovation.
Postdoctoral Scholars and Fellows: UNCW postdocs may serve as PIs or PDs on UNCW Sponsored Projects only when it is a requirement of the sponsor or requirement of the Sponsored Program. In these cases, a faculty mentor must be identified in the university’s sponsored program electronic records (OSPREY). Postdocs are eligible to serve as a Co-PI on sponsored projects when allowed by the sponsor and with approval from Department Chair or School Director and the appropriate Dean/Director/Vice Chancellor, and the Associate Provost for Research and Innovation.
Students: UNCW students (undergraduate and graduate) may serve as a PI, Co-PI, or PD on UNCW Sponsored Projects only when it is a requirement of the Sponsored Program. In these cases, a faculty mentor must be identified in the university’s sponsored program electronic records (OSPREY). When allowed by the program, a faculty typically serves as a Co-PI on the sponsored project.
Except as otherwise provided in this policy, individuals who are not paid employees or enrolled students of the university cannot serve as a UNCW PI, Co-PI, or PD.
Co-Investigator Eligibility
In the context of a Sponsored Project, the Co-Investigator’s work is under the direction of the PI, Co-PI, or Director, as applicable. All UNCW employees, students, and affiliates (e.g., adjunct professors) are eligible to serve as Co-Is on Sponsored Projects. In some cases, a Co-I may be employed or affiliated with the grantee organization or another organization participating in the Sponsored Project under a consortium agreement.
External Support of UNCW Work
Before external sponsored program support is sought or accepted by UNCW, PIs, Co-PIs, PDs, and Co-Is, as applicable, should discuss the planned work with their responsible supervisor (e.g., Department Chair or School Director) to ensure that this work is appropriate for their job duties and that the required effort is available in their assigned workload. Final supervisor approval is signified with the approval of a Sponsored Project proposal in OSPREY. Once UNCW accepts a Sponsored Project, a PI, Co-PI, PD, and/or Co-Is, as applicable, has an obligation to complete the Sponsored Project as stated in the workplan, including filing reports as called for by the Sponsored Project agreement.
UNCW employees are prohibited from committing UNCW to any Sponsored Project agreement without the required AOR approval.
Exclusions and Exceptions
In exceptional circumstances, individuals may seek an exception or variance for PI, Co-PI, and PD eligibility guidance in this policy. Formal requests for an exception or variance must be submitted in writing to the Associate Provost for Research and Innovation for consideration. The request must explain the rationale and need for the exception and include an academic style curriculum vitae (CV) for all individuals seeking to serve as a PI , Co-PI, and/or PD on a Sponsored Project at UNCW. These requests must include written approval from one or more of the following, as applicable: the relevant Department Chair/School Director, the Dean, Director, or Vice Chancellor. These requests must be considered and approved prior to SPARC’s review and authorization to submit a sponsored program proposal for external review.
Before authorizing an exception, the Associate Provost for Research and Innovation, in consultation with relevant university leadership, will consider the following:
Sanctions for Non-compliance
PI, Co-PI, and/or PD status may be suspended or permanently revoked by their supervisor or the Associate Provost for Research and Innovation though written notification to the PI, Co-PI and/or PD and the AOR. Cause for Revocation may include, but is not limited to, failure to successfully meet PI, Co-PI, or PD responsibilities, research or fiscal misconduct, or non-compliance with institution or sponsor requirements. The cause of Revocation must be included in the notification.
Given the AOR institutional authority and responsibilities, it is required that the AOR review and approve all Sponsored Projects. As such, UNCW may choose not to honor obligations undertaken by PIs, Co-PIs, and/or PDs that have not been properly authorized by the AOR. Further, UNCW reserves the right to refuse to submit a proposal, or to withdraw a proposal after submission if the proposal is found to be in conflict with existing UNCW policies and procedures, or it is determined that UNCW cannot comply with the sponsor’s requirements. If, at any time, the AOR does not have sufficient information to assure compliance with any required representations or certifications, the AOR reserves the right not to execute the certification documentation regardless of proposal deadlines or the amount of funding at stake.
Appeal
Individuals may appeal the Revocation of PI, Co-PI, and/or PD status by submitting a written appeal (Appeal) to the Associate Provost of Research and Innovation within ten (10) business days of receipt of the Revocation. The Appeal must identify any associated Sponsored Project(s), the name of the individual, the date of the Revocation, the reason for the Revocation, and the reason the Revocation should be overturned. The Associate Provost of Research and Innovation will then appoint an ad-hoc review committee to review the Appeal and make a recommendation to the Associate Provost of Research and Innovation, who will make a final determination. The ad-hoc review committee will consist of at least three university employees and include representation from the Faculty Senate Research Committee. All final decisions shall be communicated to the individual seeking the Appeal in writing within forty-five (45) business days following the Appeal. If the Appeal is approved, then the individual’s PI, Co-PI, or PD status shall immediately be reinstated. Otherwise, the Revocation shall stand. If the Appeal is rejected, the decision can be Appealed to the Provost and Vice Chancellor for Academic Affairs in writing within five (5) business days for final determination.