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Sponsored Projects

P7-200A: PI Eligibility Exceptions

Purpose

This procedure establishes how departments and colleges request and document exceptions to Principal Investigator (PI) eligibility requirements under University Rule R7-200B: Principal Investigator Eligibility and Responsibilities in Sponsored Projects.

This procedure does not modify PI eligibility requirements established in Rule R7-200B; rather, it describes the process for obtaining and documenting approvals when an individual is not automatically eligible to serve as a PI or Co-PI.

Authority

This procedure supplements Rule R7-200B: Principal Investigator Eligibility and Responsibilities in Sponsored Projects. In the event of a conflict between this procedure and University regulations, the University regulation shall control.

Applicability

This procedure applies to individuals seeking to serve as a PI or Co-PI on a sponsored project and who are not automatically eligible under Rule R7-200B. 

Examples may include:

  • University employees who are not faculty members;
  • Individuals seeking an exception from the eligibility requirements established in Rule R7-200B; or
  • Current PIs who voluntarily separate from the University and seek approval to continue serving as PI for a limited transition period. 
Research associates, postdoctoral fellows, and graduate students may serve as PI applicants when applying to sponsor programs specifically designed for such individuals, provided appropriate faculty mentorship and supervision are established as required by Rule R7-200B. Requests meeting these criteria do not require a PI eligibility exception under this procedure. Requests involving sponsor programs not specifically designed for such individuals may require review under this procedure.
 

PI Eligibility Determinations

University job titles do not always correspond with faculty status or PI eligibility. Eligibility is determined based on an individual's University appointment and applicable University regulations.
 
Departments and colleges are responsible for determining whether an individual meets the eligibility requirements established in Rule R7-200B, obtaining any required approvals, and ensuring that requests submitted under this procedure contain appropriate supporting documentation.
 
OSP may request documentation of the applicable approvals but does not independently verify appointment classifications or eligibility determinations made by departments, colleges, or approving officials.
 

Departmental Responsibilities

Before endorsing an exception request, the administering department, center, institute, or other administrative unit should evaluate:

  • The individual's qualifications, expertise, and experience;
  • The individual's ability to fulfill PI responsibilities;
  • Availability of administrative, financial, and research oversight;
  • Availability of resources necessary for successful project performance, including space, technology, data management support, and administrative assistance where appropriate;
  • Any institutional, compliance, financial, or reputational risks associated with the request; and 
  • Sponsor-specific eligibility requirements.

Departmental endorsement signifies that the unit is willing to support the proposed PI and provide appropriate oversight and resources if an award is made. 

Nothing in this procedure limits the authority of departments, colleges, or University leadership to decline support for a proposal when resources, oversight, or institutional considerations do not support the request. 


Instructions to Request an Exception

  1. Prepare Written Request
    The request should originate from the department chair, institute director, center director, or equivalent unit leader responsible for administering the project.

  2. Obtain Required Approvals
    The request must be endorsed by the cognizant department chair and college dean (or equivalent officials) and include documentation supporting the requested exception.

  3. Submit to OSP 
    Submit the request to the Sponsored Projects Officer listed on the Document Summary Sheet. OSP serves as the Vice President for Research's designee for purposes of administering, documenting, and approving PI eligibility exception requests.

    OSP may approve, deny, or request additional information regarding an exception request.

Required Documentation

Exception requests should include:

  • Name, title, department, and uNID of the proposed PI
  • Project title
  • Sponsor name
  • Proposal deadline, if applicable
  • eProposal/DSS number, if available
  • Justification for the requested exception
  • Description of the individual's qualifications and role on the project
  • Documentation that the administering department or unit accepts responsibility for providing oversight, resources, and support necessary for the conduct of the project
  • Description of any planned mentoring, supervision, or oversight arrangements, if applicable
  • Concurrence from the individual's home department or unit, if the individual's primary appointment resides elsewhere
  • Current curriculum vitae or resume

Proposal Routing and Documentation

  • Required exception approvals must be obtained before proposal submission or award acceptance.
  • Documentation of the approval must be retained in the proposal record and attached within eProposal.
  • OSP may request evidence of approval before submitting a proposal or accepting an award.
  • Departments are responsible for ensuring the appropriate approval pathway under Rule R7-200B has been followed.

Approval

Sponsored Project Officers will route requests to the OSP Director for institutional review and approval, acting under delegated authority from the Vice President for Research.

Approval of a PI eligibility exception:

  • Applies only to the project, proposal, or award identified in the request unless otherwise expressly stated.
  • Does not establish permanent or ongoing PI eligibility.
  • Does not guarantee approval of future proposals.
  • May be modified, limited, or revoked if institutional circumstances, appointment status, sponsor requirements, compliance concerns, or project oversight arrangements materially change.


Related Policies and Procedures

 

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Last Updated: 11/2/26