Change in Status of Principal Investigator/Key Personnel

Many sponsors require advance notification or require prior approval be obtained before "key personnel" or the Principal Investigator reduces his or her effort on a grant from the proposed amount. The general federal rule is stated in OMB Circular A-110, the "Uniform Administrative Requirements for Grant and Agreements with Institutions of Higher Education, Hospitals and Other Non-profit Organizations"

Examples of the implementation of this policy include:

National Institutes of Health (NIH) - "The grantee is required to notify NIH if the PI or other key personnel named in the NGA will withdraw from the project entirely, be absent from the project during any continuous period of 3 months or more, or reduce his or her time devoted to the project by 25 or more percent from the level that was approved at the time of award (for example a proposed change from 40 percent effort to 30 percent or less effort). NIH must approve any alternate arrangement, including any replacement PI or other key personnel proposed by the grantee." (See GIM 18, Attachment A, Part 2 -- " Changes in Project")
National Science Foundation (NSF) - "If a named Principal Investigator or Project Director plans to or becomes aware that he or she will: (1) devote substantially less effort to the work than anticipated in the approved proposal (defined as a reduction of 25% or more in time); (2) sever his or her connection with the awardee organization; or (3) be absent for a continuous period of three months or more, or otherwise relinquish active direction of the project, he or she shall advise in writing both the NSF Program Officer and awardee's Authorized Organizational Representative. Action appropriate to the situation will be initiated in accordance with the guidelines described in GPM Section 312." (Quoted from "NSF Online Documents")

Other sponsors may have similar guidelines and their grants manuals should be consulted. Campus departments are responsible for monitoring compliance with these regulations and for sending a letter to the sponsor which must be counter-signed by Office of Sponsored Programs seeking prior approval when necessary.

Questions about these policies can be directed to Grant and Contract Accounting at 3-8454 or Office of Sponsored Programs at 3-4043.

Compliance Grant & Contract Glossary