Chapter 2: Research Personnel

2.1 Research Personnel

2.1.1 Principal Investigator Eligibility

The Principal Investigator (PI) or Program Director (PD) is the individual(s) approved by Duke University to oversee the fiscal, programmatic, and administrative aspects of a sponsored project. Grants, contracts, and other binding agreements are awarded to the institution, and the PI/PD is directly responsible and accountable to the University and the sponsor for the proper conduct of a sponsored project, which includes but is not limited to 1) scientific and technical direction, 2) resource allocation, 3) financial stewardship, 4) administrative and personnel oversight, 5) programmatic reporting, and 5) adherence to all governing sponsor and University policies and regulations.

I. PI Eligibility at Duke

Only those individuals with whom the University has or intends to have an ongoing employment relationship may serve as PI/PD on projects, research or otherwise, supported by external funding sources at Duke. Individuals employed full-time at other institutions may not be PI/PD on sponsored projects at Duke University.

Members of the Duke regular rank faculty (as defined in Chapter 3 of the Faculty Handbook) in good standing with the University are eligible to serve as PI/PD as a matter of privilege on sponsored projects at Duke. Individuals who are not regular rank faculty members may be granted eligibility to serve as PI/PD with the prior approval of the appropriate institutional official or office. Further information on seeking prior approval may be found in the process for requesting PI eligibility. PI eligibility is also subject to sponsor requirements and restrictions.

II. PI Eligibility for Awards Based at Other Institutions

Faculty with a primary appointment at Duke University may not serve as lead (or “contact” or “overall”) PI/PD on applications and awards based at other institutions, unless the faculty member is on leave and has received appropriate institutional approvals for the activities; this is also true for other Duke investigators (e.g., research staff and trainees). Such outside sponsored activities must be awarded to Duke via a research agreement and appropriately disclosed according to Conflict of Interest requirements.

III. Restrictions, Suspensions, or Revocation of PI Eligibility

The University may, under certain circumstances, restrict, suspend or revoke PI privileges of otherwise eligible individuals. Reasons for restriction include but are not limited to: (1) current investigation into possible misconduct; (2) findings of misconduct; (3) history of failure to meet deliverables or reports on current or past sponsored projects in a timely and orderly fashion; (4) unmanageable impairment of objectivity; (5) fiduciary improprieties; (6) actions by third parties warranting such actions; etc.

2.1.2 Principal Investigator Roles and Responsibilities

While the University is ultimately responsible for fiscally compliant management of all sponsored projects, it is the principal investigator (PI) or program director (PD) who bears primary responsibility for directing both the research and administration of a grant, cooperative agreement, training or public service project, contract, or other sponsored project.

• The PI/PD is responsible for the completion, accuracy, and timely submission of all programmatic reports required by the sponsor.
• The PI/PD is responsible for ensuring that all financial aspects of the project are done in a timely manner so that financial reports can be submitted by the Office of Sponsored Programs (OSP) as required by the sponsor.
• In consultation with the department chair, the PI/PD ensures sufficient financial administrative oversight to manage the financial and other administrative functions related to the grant.
• In conjunction with the departmental financial administrator, the PI/PD ensures compliance with all applicable financial and administrative regulations and University policies and procedures.
• The PI/PD is responsible for validating their own effort certification report in accordance with Duke’s General Accounting Procedures and for validating the effort certification for any staff who work under the PI/PD’s supervision.
• The PI/PD is responsible for ensuring that the programmatic and financial management of subrecipients associated with their funded projects conduct assigned research and reporting appropriately and in a timely, accurate, and financially responsible manner.
• In conjunction with OSP, the PI/PD approves final payment to subcontractors.

2.1.3 Investigator Communication with Sponsor Personnel

Duke University encourages as-needed communication between investigators and external sponsor program officials on matters related to science and research. When sponsoring entities – federal, foundation, or industry – communicate funding procedural, or final budget decisions, any appeal of those decisions must be made through an Authorized organization representative (AOR). Investigators, including faculty and staff, are not authorized to contact sponsors directly about administrative matters. If an investigator wishes to appeal a sponsor decision, the investigator should alert the grant manager who will submit the request and justification for the appeal to their representative in the Office of Research Support (ORS) or the Office of Research Administration (ORA). If the situation requires additional management or institutional response, the Incident Response & Issue Resolution Committee will manage the related interaction as appropriate. If Duke agrees to process the appeal, the investigator and the grant manager will be notified as soon as the sponsor provides Duke with a decision.

2.2 Effort & Compensation

As an applicant organization and recipient of external research funding, Duke University assumes responsibility for verifying compliance with sponsor policies and guidelines, including requirements to properly estimate, budget, allocate, track and report personnel effort expended on sponsored projects.

2.2.1 Effort Commitment Guidelines

Federally-funded sponsored projects requires Principal Investigator and key personnel named in an award to propose and maintain a reasonable, measurable level of effort, commensurate with the individual’s specified roles and responsibilities on the sponsored project, given the individual’s appointment type and sponsor expectations. The effort needs to be reflected via the individual’s payroll distribution. For other types of sponsored projects, individuals should maintain reasonable effort specifically associated with each project. Further information on reasonable effort may be found on myRESEARCHpath.

All individuals with measurable effort on sponsored projects must ensure that their annual effort certification accurately reflects their activities. General Accounting Procedure 200.170, Effort Reporting, provides further details on effort reporting and certification procedures.