Principal Investigator: Roles and Eligibility

U-M principal investigator

The U-M PI is a U-M employee with the background and training in scientific and administrative oversight necessary to conduct and manage a sponsored project. The individual must be treated by the appointing unit as an independent investigator and by U-M as a non-temporary employee. The expectation is that eligible U-M PIs will submit proposals through their primary appointing unit, unless the units involved have other explicitly approved other arrangements.

The U-M PI is considered independent if they have the authority, responsibility and financial resources to initiate, direct and manage their own research projects. Independent investigators must be tenure-track faculty (instructor through professor) or research faculty (research investigator through research professor), or hold a clinical professorial appointment. With unit approval, emeritus faculty may also be appointed as U-M PIs.

The PI’s responsibilities include, but are not limited to, ensuring:

• Research and scholarly activity is conducted with the highest degree of integrity.
• Project results are reported accurately and completely.
• Project reports are completed and submitted to the sponsor as required.
• Signatures, disclosures and certifications are provided as required.
• Research funds are spent in accordance with University and sponsor guidelines.
• University resources are utilized appropriately and with institutional approvals.
• All protocols related to the use of human and animal subjects are followed.
• Occupational and lab safety protocols are followed properly.

Who can or cannot serve as U-M PI?

• Tenure-track or research faculty are permitted to serve as U-M PIs on sponsored projects.
• Individuals who are not paid employees of U-M cannot serve as a U-M PI.

eResearch definitions of PI and other key personnel

Definitions for PI, participating investigators, key/senior personnel or non-faculty investigators can be found in the eResearch Proposal Management System’s help text. Visit Proposal Management: Additional Help: 2.3 for more information. Also see Standard Practice Guide 500.01: Fiscal Responsibilities and the Research Ethics and Compliance FAQ on Who is considered an “investigator” for purposes of outside interest disclosure?.

Sponsor principal investigator

A U-M sponsor PI is a U-M employee or U-M student who meets the eligibility requirements of the sponsor. In most cases, the PI-eligible by both the sponsor definition and the U-M definition are the same individual and are named in the U-M Principal Investigator field of the proposal approval form (PAF) within the eResearch Proposal Management (eRPM) system.

When an individual does not qualify as both the sponsor PI and U-M PI, both must be named separately on the PAF in these fields:

• U-M Sponsor Principal Investigator (Sponsor PI)
• U-M Principal Investigator (PI)

U-M will allow anyone employed by U-M who meets the sponsor’s guidelines for eligibility to serve in the sponsor PI capacity. U-M will recognize that individual as the U-M PI as long as the employment criteria and level of independence associated with the current job title as defined above is met.

Certain sponsored project competitions may be directed specifically to the fund or may support individual students, fellows or other non-permanent employees. Examples:

• Doctoral dissertation awards 
• Individual pre-and postdoctoral fellowship programs

The proposal format of these typically requires that the individual applicant (e.g., the student or fellow) be identified in the application as the PI in those cases.

If the sponsor PI does not meet U-M’s criteria for U-M PI, another individual meeting the requirements must be named to provide internal guidance and leadership for the scientific, technical, administrative and financial aspects of a sponsored project.

Other PI titles: Project director, program director

Typically, the term principal investigator shall encompass other sponsor-specific titles such as project director and program director, terms commonly used for non-research sponsored projects. In these situations, one individual will be identified on the PAF as the Sponsor Principal Investigator. The designation only should be used to identify the person leading the proposal on the PAF when the term PI is not used in the proposal.

Exceptions to PI eligibility

Exceptions to the PI eligibility limitations described above may be granted by the school/college/institute/center ultimately responsible for the conduct of the sponsored project as indicated by approval of the dean or their designee in the PAF to which the exception applies. The Office of Research and Sponsored Projects (ORSP) reserves the right to deny exceptions for ineligible PIs where reasonably necessary to protect the interests of the University.

In order to grant an exception, the approving school/college/institute/center must ensure that the following criteria are met:

• The investigator has sufficient resources/facilities to carry out the project.
• The investigator is a paid employee of U-M.
• The investigator’s role on the project will fall within their employment duties for the U-M.
• The investigator has appropriate/applicable licensure or other credentials required for performance of the work.

By approving the PAF, the school/college/institute/center agrees that it will assume responsibility for ensuring the fiscal and programmatic obligations of the award are met if the PI is unable to do so.

Examples of exceptions:

• Adjunct faculty (instructional and research) with a paid U-M appointment. The scope of work for the project must be within the scope of the individual’s paid appointment. The paid appointment makes it clear that the PI is acting within the scope of their employment and ensures that they are subject to and covered by, all relevant laws, policies, and procedures (e.g., SPG’s 303.03, 303.04, 500.01, 601.09, and the Michigan Freedom of Information Act).
• Heads of non-research and non-teaching units for projects considered within the scope of their duties.
• Individuals who are not permanent or independent but for whom the promotion to an eligible position, before award, is assured by the department and the school. (Noted on the PAF by adding a future appointment in the U-M Investigators detail section.)
• Individuals who have accepted PI-eligible positions at U-M, but who are not yet employees and whose U-M appointment will be effective on or after the proposed effective date of the sponsored project. (Noted on the PAF by adding a future appointment in the U-M Investigators detail section.)
• Lecturers’ Employee Organization lecturers may be eligible in another title with an additional appointment. Please contact Academic HR for guidance.

This is not an exhaustive list and each unique situation should be assessed based on the facts and circumstances of the particular exception request.

Multiple principal investigators

Two or more U-M PIs can be designated for a project if the sponsoring agency explicitly permits multiple PIs (sometimes called co-PIs). The multiple PIs share authority for leading and directing the project, intellectually, logistically and financially. Each PI is responsible and accountable for the proper conduct of the project, including the submission of all required reports. The designation of multiple/co-PIs for a single project diminishes neither the responsibility nor the accountability of any individual PI. One of the multiple PIs must be designated as the Contact Principal Investigator within eRPM and sponsor systems.

Signing PAF and award activity

All investigators are expected to sign the PAF prior to proposal submission as well as the Award activity. See the Sign PAF/Sign Award Record Activity page for more information.

Note that this differs from the signature authority that U-M grants to ORSP and other U-M officials. PIs do not have the authority to sign on behalf of the University.

All sponsored projects are formally awarded to the Regents of the University of Michigan. Consequently, a PI may not enter into any agreement without the approval of the department chair, dean and ORSP.

Replacing a PI when PI moves

If a U-M PI leaves the University prior to the end of a sponsored project, leadership arrangements for the duration of the project should be discussed with the unit, ORSP and the sponsor, in advance of departure.

If the sponsored project is not being transferred to the PI’s new institution, a replacement PI must be named. See the Post-award Change Request Form (PI/Key Person Change section) for guidance on this process.