Who is Considered an Investigator and Needs to Disclose SFI?
Guidance on this page will help in identifying who on a sponsored research project is an Investigator for the purposes of collecting Significant Financial Interest (SFI) disclosures.
Contributions individuals make to research projects and programs help determine their Investigator status. Ultimate determinations of Investigator status are the responsibility of the Principal Investigator.
Review the definition of Investigator, guidance on roles Always Considered an Investigator, and It Depends Checklist to help with this determination.
Note: Investigators are required to adhere to federal rules of financial conflict of interest.
Definition of Investigator
The UW GIM 10: FCOI policy defines “Investigator” at the UW.
“Investigator” means any University personnel regardless of title or position, including a University Research Employee, responsible for the design, conduct, or reporting of University Research.
Investigator includes, but is not limited to, the Principal Investigator, project director, co-principal investigator, and may also include other Senior/Key Personnel, a postdoctoral fellow, graduate student, trainee, staff member, collaborator, or consultant, depending on the person’s role in the Research.
The primary factors to be used in determining who is an Investigator are the significance of the tasks assigned to the individual with regard to the design, conduct and reporting of the Research and the degree of independence that individual may have in performing such Research-related tasks.
The Public Health Service (PHS) Financial Conflict of Interest (FCOI) regulation applies to all individuals defined as project Investigators.
Determinations of Investigator status are distinct from determining PI Eligibility, which is managed by Schools/Colleges.
Always Considered an Investigator
Some individuals with specific roles are ALWAYS considered Investigators and must disclose Significant Financial Interest (SFI).
- Principal Investigator (PI)
- Includes Multiple PIs and Administrative PI
- Sponsor for Postdoctoral or Graduate Fellows
- Postdoctoral or Graduate Fellows paid on fellowships
- Identified as “Application PI” on eGC1 PI/Personnel and Organizations page
- Mentor named in Career Development Grants
Subrecipients, while also always considered investigators, must comply with the FCOI policy of their home institution.
Other Roles Considered Investigator
IF these roles have been named Senior/Key Personnel they are also ALWAYS considered an Investigator.
- Postdoctoral / Graduate Fellows on Training Grants
- Postdoctoral or Graduate Students on Research Grants
If these individuals have NOT been named Senior/Key Personnel review the It Depends Checklist.
It Depends Checklist
If ANY of following questions can be answered “YES” for individuals they ARE considered an Investigator.
☐ Is the individual responsible for the design of the research?
☐ Is the individual responsible for the conduct of the research?
☐ Is the individual responsible for the reporting of research?
☐ Is the individual responsible for the programmatic outcomes?
☐ Will the individual be a collaborator on a publication related to the research? For example: Will they be listed as an author on a publication that cites the grant as a ‘Funding Source’?