Principal Investigator (PI) Eligibility Administrative Procedures
Faculty and authorized professional research staff are encouraged to seek external financial support for specific projects undertaken to further the mission of the University in teaching, research, and public service. The purpose of University research is the discovery and dissemination of new knowledge. Sponsored projects enhance and expand the educational opportunities available to undergraduate and graduate students at the University, promote research, scholarly inquiry, and the development of new knowledge, contribute to the academic achievement and stature of the institution, and assist the university in fulfilling its responsibilities to the state and the nation.
Upon submission of a grant or contract to an external sponsor, the University assumes responsibility for the proper performance of the stated project, the fiscal management of the funds received, and accountability to the sponsor. Much of these obligations are vested in the principal investigator (PI) by the University. For this reason, it is essential that the University identify which ranks and appointments are entitled to the privilege of serving as PI.
A principal investigator (PI) is the lead scientist for a particular well-defined science or other academic project, who takes direct responsibility for the overall design, conduct, and reporting of the research or other externally funded sponsored activity. In addition, the PI is responsible for all regulatory requirements and review.
The Office of Sponsored Projects (OSP) serves as the coordinating office for externally funded research and sponsored projects at The University of Texas at Austin. The goal of OSP is to assist faculty and professional research staff in their efforts to secure and ensure proper stewardship of external funding by conducting proposal review, authorization and submission; award negotiations and acceptance; account management; close-out, reports, audits, collection; professional development and education; and export control and research compliance.
A PI is authorized to apply for research funding through OSP, and to conduct research in an ethical manner after the University has accepted the award on his/her behalf.
A PI or Co-PI is not authorized to submit a proposal directly to a sponsor without OSP approval, accept an award on behalf of the University, or to sign contracts/agreements on behalf of the University. Any negotiations associated with an award must be conducted by the Office of Sponsored Projects (OSP).
- 3. Eligibility
3.1 Titles Eligible for Automatic PI Status
Automatic PI status is granted to tenured or tenure-track faculty, who hold the following titles (Regents’ Rule 31001):
- Associate Professor
- Assistant Professor
Other non-tenured professional research titles may also qualify for automatic PI status (see HOP 7-1020 – Research Titles), provided the individual is a paid employee (see Table 3.1.A. below for a list of titles with automatic PI status).
For those who have automatic PI status, please submit an ERA Help Ticket to obtain access to the Research Management System (RMS). Individuals must provide the department name to which their awarded grants will be credited to ensure an accurate unit code is created.
Exceptions to serve as PI or Co-PI must be requested for:
- Non-tenure track faculty
- Employees holding titles not eligible for automatic PI status
- Emeritus faculty
- Newly hired faculty/researchers
To request a PI Status Exception please submit an ERA Help Ticket.
Principal Investigator requests solely for protocols reviewed by the Institutional Review Board (IRB), the Institutional Animal Care and Use Committee (IACUC), or the Institutional Biosafety Committee (IBC) on studies that are not externally sponsored or funded should be directed to the Office of Research Support and Compliance.
Table 3.1.A. The following university non-academic titles are eligible for automatic PI status provided the individual is a paid employee:
Other Research, and Administrative Titles with Automatic PI Status Job Code Senior Research Scientist 0701 Research Scientist 0702 Senior Research Engineer 0703 Research Engineer 0704 Research Associate 0708 Dean 0335 Vice Dean 0338 Associate Dean Assistant Dean Vice President Associate Vice President Assistant Vice President 0313 Vice Provost 0319 Associate Vice Provost 0321 Assistant Vice Provost 0323 Executive Director of a Unit 0457 Director of a Unit 0379 Director of a Program 0382 Director of an Academic Program 0362 **Director titles outside of Director 0379, 0382, 0362 or 0457 job code must request PI/Co-PI status exception
3.2. Titles Requiring Exception for PI Status
Persons holding the titles listed below in Tables 3.2.A through 3.2.C are not automatically granted PI status and must submit an Exception Request for PI/Co-PI status. Titles listed in Table 3.2.D are not eligible for PI status. Exceptions may be granted on a multiple submission or project-specific basis:
- Project-specific: Request for PI/Co-PI status for a specific project will endure for the life of the project.
- Multiple submission:
- Annual authorizations are approved through August 31 and require a request for renewal each year on or before September 1 (Please note: OSP does not issue annual renewal reminders), or
- Position-specific authorizations can be approved for multiple years as long as the individual holds the same appointment at the University. In this case, it is incumbent on the requesting department to inform OSP if there is a change in the status of employment requiring rescission of PI or Co-PI status.
Considerations for exceptions will include whether or not the sponsored activity will have at least one PI who is a paid employee of the University over the entire performance period of the proposed or granted awards.
Exceptions to serve as a PI are generally not granted to individuals holding without-compensation, affiliated appointments. However, research title holders at a 0% or research affiliate appointment may submit proposals as PI without a Co-PI if the submission is accompanied by a written assurance from the unit head that the individual will hold a paid appointment during the award performance period.
Newly hired faculty/researchers may request temporary PI status and may submit proposals/transfer applications without a UT Co-PI as long as the project’s start date is after their official start date. After their official start date, PI status becomes automatic.
Retired/Emeritus Faculty do not receive automatic PI approval even if PI status was held before retirement. Exceptions for emeriti will be granted on a project-specific basis. Please specify faculty type as “Emeritus” when submitting a PI Exceptions Request.
To ensure that all agency requirements are met throughout the lifetime of the project, a Co-PI must be identified who can step-in as PI for projects led by emeritus faculty should the emeritus faculty become disengaged from the project due to incapacity or absence from the University for an extended period of time. A Co-PI must be a UT employee who is PI-eligible (refer to the section titled 3. Eligibility above) and who can be actively participating in the project, a knowledgeable colleague, the PI’s Department Chair, or Associate Dean for Research for the PI’s College.
Postdoctoral fellows may serve as Co-PIs on sponsored projects, but may not serve in the role of PI. Postdoctoral fellows and adjunct faculty must seek a sponsoring PI who will submit necessary proposal documentation to OSP for review and endorsement. Should the proposal be funded, the sponsoring PI will assume budgetary and reporting responsibilities at the university level on behalf of the postdoctoral fellow or adjunct faculty member.
There are times when it is a sponsor requirement that a postdoctoral fellow serve as PI on a project, or it is most appropriate for the postdoctoral fellow to serve as PI on a project to help further their career. In cases such as these, please refer to the section titled 4. Other Consideration – PI of Record on this page for additional information. An adjunct faculty member may not be recognized as PI with a sponsor or PI of Record.
Adjunct faculty may serve as Co-PIs on sponsored projects, but may not serve in the role of PI at the University or with the sponsor. An adjunct faculty member may not serve as PI of Record, i.e. be recognized as PI on a project by a sponsor. Outgoing faculty members may keep a grant at the University, however a new PI at the University with active PI status must be appointed to the project with notification to the sponsor of the change in PI.
If a title is not listed below please submit a PI/Co-PI Exceptions Request for additional guidance from The Office of Sponsored Projects.
Table 3.2.A. Titles listed below are generally considered for PI/Co-PI status on a multiple submission basis:
Titles that may request PI status for multiple submissions Job Code Clinical Professor 0013 Research Professor 0017 Clinical Associate Professor 0024 Research Associate Professor 0027 Clinical Assistant Professor 0034 Research Assistant Professor 0037 Lecturer 0050 Engineering Scientist 4204 Instructor 0040 Instructor (Medical) 0240 Instructor in Clinical Nursing 0041 Instructor in Clinical Pharmacy 0042 Instructor of Medicine (Clinical Scholar) 0244 Instructor of Medicine (Clinical Educator) 0243 Professor of Instruction 0007 Associate Professor of Instruction 0023 Assistant Professor of Instruction 0038 Professor of Practice 0014 Associate Professor of Practice 0023 Assistant Professor of Practice 0033 Senior Research Fellow 0705 Research Fellow 0706 Senior Engineering Scientist 0707 Engineering Scientist Associate 4205 Research Engineering/Scientist Associate V (E) 4207 Research Engineering/Scientist Associate IV E 4208 Research Engineering/Scientist Professional (Part Time) 4223
Table 3.2.B. Titles listed below generally considered for PI/Co-PI status on a project-specific basis:
Titles that may request PI status on a project-specific basis Job Code Research Affiliate - Sr. Research Fellow A012 Research Affiliate - Research Fellow A011 Program Director 0381 Program Manager 0367 Program Coordinator 8105 Project Director 0371 Project Manager 0361 Project Manager 9109 Project Coordinator 0489 Professor Emeritus 0000 Professor Emeritus (Medical) 0200 Professor of Instruction Emeritus 0006 Professor of Practice Emeritus 0005 Associate Professor Emeritus 0018 Associate Professor Emeritus (Medical) 0218
Table 3.2.C. Titles listed below may request Co-PI status on either a multiple submission or project-specific basis:
Titles that may serve as Co-PI only Job Code Adjoint Professor 0019 Adjoint Associate Professor 0029 Adjoint Assistant Professor 0039 Adjunct Professor 0015 Adjunct Associate Professor 0025 Adjunct Assistant Professor 0035 Researcher 0710 Research Affiliates - Postdoctoral A010 Researcher Fellow 0711 Postdoctoral Fellow 0712 A&P Hourly Employment 0520 Research Engineering/Scientist Associate III E 4209 Research Engineering/Scientist Associate II E 4210 Research Engineering/Scientist Assistant 4222
Table 3.2.D. Titles listed below may NOT be considered a PI or Co-PI:
Titles that are not eligible to serve as PI or Co-PI Job Code Visiting Researcher/Scholar A006 Visiting Professor 0012 Visiting Associate Professor 0022
3.3. Procedures to Request Exception for PI Status
The individual’s department (Dean, Associate Dean for Research, Department Director or Chair) must submit a PI/Co-PI Exception Request to OSP.
The following requirements will be necessary to obtain a PI/Co-PI Status Exception:
- Acknowledgement that the proposed PI/Co-PI has read and agrees to abide by Researcher Responsibilities.
- The individual seeking PI status will also need to be compliant with the University’s policy:
- Written assurance from the unit head that the individual will hold a paid appointment during the award performance period will be required on requests for individuals with 0% or research affiliate appointments.
The request as recommended by the appropriate unit head is reviewed and approved by the Office of Sponsored Projects.
Additional Department-Specific Exception Request Requirements May Be Necessary for the Following Colleges:
College of Liberal Arts requests must be routed through the relevant department chair, and then the College’s Research and Graduate Studies Office (firstname.lastname@example.org) prior to forwarding to OSP.
Dell Medical School PI Exceptions requests must be routed through Lindsey Demeritt, Associate Director of Sponsored Research, Dell Medical School (email@example.com; 512-495-5500) prior to contacting OSP.
College of Pharmacy PI Exceptions must be routed through the Office of Research and Graduate Studies via Jennifer Bindel, Senior Grants and Contracts Specialist, (firstname.lastname@example.org; 512-232-7511) prior to contacting OSP.
College of Education requests must be routed through the appropriate COERA staff member (see COERA wiki for contacts). They will assist in preparing the exception request and then route to the COE Associate Dean for Research for documented approval. COERA will then submit to OSP and include ADR’s approval email along with other necessary documentation.
- 3.1 Titles Eligible for Automatic PI Status
4. Other Consideration - PI of Record
Certain sponsors and program guidelines require a graduate student or postdoctoral fellow to act as a Principal Investigator (PI) (i.e., NIH, HRSA, etc.) and will be recognized as such in the sponsor’s proprietary system, such as NIH eRA Commons.
This is meaningful to the student / postdoctoral fellow because the official sponsor record and award documents will reflect the graduate student or postdoctoral fellow as the project PI and will show that the graduate student or postdoctoral fellow has agreed to conduct the proposed research as required by program guidelines. Under these circumstances, OSP refers to the graduate student or postdoctoral fellow in the University’s internal systems as PI of Record and requires a faculty mentor to shepherd the proposal and award through internal systems. All internal records will reflect the faculty mentor as the primary PI; the faculty mentor PI is ultimately responsible to the University for the technical and fiscal oversight of the project. A formal request for exception is not necessary to be listed as PI of Record on internal records.
An adjunct faculty member may not serve as PI of Record or be recognized as PI on a project by a sponsor.