- PIs are discouraged from listing project participants other than the PI and Co-PI as “Key” since named “Key Persons” incur additional burden and audit risk.
- PIs and DLCs are responsible for maintaining the list of “Key Persons” associated with every project.
- No changes should be made to the PI, Co-PI or Key Persons on a project before first checking with OSP.
- Annual Conflict of Interests disclosures and effort tracking are required for named Key Persons by some Sponsors.
Key personnel are those people who are essential to carrying out the work of a project, typically those responsible for the design, conduct and reporting of the research. Key personnel includes: PIs, Co-PIs, and a third category known as “Key Persons”.
MIT’s policy is that the PI and any Co-PIs for a project, as well as fellows on any Fellowship proposal, must be included as key personnel. PIs are discouraged from listing other people as Key Persons at proposal stage due to the increased administrative burdens imposed by the sponsor and the additional audit risk to MIT.
Sponsor requirements for tracking key people vary widely – see the sponsor-specific guidance below. Most federal sponsors require that we track effort for key personnel and notify sponsors when there is a significant reduction in effort (25% or more) or when one of the key people leave the project. Several federal and foundation sponsors require that key personnel keep current on conflict of interest disclosures of financial interest and conflict of interest training.
PIs and DLCs are responsible for tracking effort for key personnel and notifying the sponsor of significant changes. Such requests should be sent in writing to OSP for review and approval before they are submitted to the sponsor.
Key Personnel at Proposal Stage
Sponsor guidelines spell out who MUST be named as “key” at the proposal stage. MIT guidelines spell out which titles are equivalent to a PI or Co-PI role. MIT recommends that additional people not be listed as “Key Persons” on proposals – this does not diminish the individual’s role or the importance of the individual to the project.
For NIH/PHS proposals, Kuali Coeus (KC) will recognize those Key Persons that have a role requiring certification on the proposal, and the system will prevent routing until this step is completed. More information and instructions may be found on the “Kuali Coeus: Investigators & Key Persons Certifications NIH/PHS Sponsor Proposal Quick Reference Card”
For non-NIH/PHS proposals, Sponsors generally do not require certification of key personnel other than the PI and co-PI. However, if a specific solicitation requires all named Key Persons to complete a COI disclosure, the Aggregator must check the “PCK” flag on that proposal (in the “Supplemental Information” section). Detailed information and instructions for selecting the “PCK” flag at proposal stage is found on the “Kuali Coeus Certifying Key Persons and Fellows Quick Reference Card”
For Fellowship proposals, most fellowships require the faculty mentor to be the named PI and the graduate or postdoctoral fellow to be named in the role of Key Person to reflect the fellow’s responsibility for conducting his/her research. Fellowship proposal processing guidelines can be found here.
Key Personnel at Award Stage
OSP will contact the PI/DLC at award stage when verification of Key Persons is needed. Key Person(s) may be required to provide additional disclosures or complete training requirements before the award is activated, depending on the Sponsor’s policies.
For NIH/PHS awards, or awards where the “PCK” flag was checked on the proposal: Key Person(s) first need to be confirmed in the KC system by the DLC Administrator or PI via Key Person Maintenance. Detailed information and instructions for confirming may be found on the “Kuali Coeus Key Person Maintenance Quick Reference Card”.
Once Key Person(s) have been confirmed, the KC system will then check that the COI disclosures and COI training requirements have been completed for the confirmed Key Person(s).
For instances where Key Persons were not first named on the development proposal, and need to be added to the Award, please contact email@example.com and your OSP Contract Administrator for assistance.
Refer to the sponsor guidelines and the Notice of Award for more information. OSP can help interpret the Sponsor’s policies.
Managing Key Personnel for the Life of the Award
Remember – if you plan to reduce the effort of key personnel named in a Notice of Award by 25% or more of their previously approved effort, you must notify OSP and you may need to write to your program officer to request prior approval of the reduction. Such requests should be sent in writing to OSP for review and approval before they are submitted to the sponsor.
If the PI has discussed the intended change with the sponsor, please provide any relevant correspondence to your OSP representative. In some cases, the change may need to be submitted to OSP as a Supplement proposal in Kuali Coeus so that any new personnel can complete a certification. Any reduction in effort that is less than 25% of the previously approved effort may be reported in your next progress report, if required. Your OSP representative can advise you on what is needed.
In addition, DLC administrators should consider whether the intended change will have an impact on cost sharing commitments, if any, and should work with PIs to ensure that all required progress reports have been submitted to the sponsor prior to the departure of project personnel.
Frequently Asked Questions
How will we track key persons?
The KC System keeps track of individuals in the Key Persons role via “Key Person Maintenance” in the Award module, for those individuals named Key Person on an NIH/PHS proposal or those proposals where the “PCK” flag was selected. Additional information and instructions may be found on the “Kuali Coeus Key Person Maintenance Quick Reference Card”
Remember – if you are reducing the effort of key personnel named in a Notice of Award by 25% or more of their previously approved effort, you must notify OSP and write to your program officer and request prior approval of the reduction. Any other reduction in effort may be reported in your next progress report.
Who can maintain key persons?
In addition to the Principal Investigator, anyone with the KC Authorization “Maintain Key Person” may maintain this information. This role will allow an administrator to edit the Key Person(s) information for all awards in their unit.
To request this KC authorization, users should inquire with their Primary Financial Authorizer in their DLC – this person has the ability to grant KC authorizations via the Roles DB. More information may be found on the Training tab of the KC website here: http://kc.mit.edu/training/getting-started-guide/how-do-i-begin-using-kuali-coeus
We understand that there are situations where you may want to grant an administrator authorization for the awards of a single PI or group of PIs, but at this time, these KC authorizations are granted for the Unit.
Who needs to review and track key personnel?
PIs/DLCs are responsible for reviewing and confirming key personnel on new awards and for tracking effort for key personnel throughout the project period.
If, during the life of an award, any of the key personnel reduce their effort by 25% or more, or leave the institute and/or new key personnel are added to the award, see above: Managing Key Personnel for the Life of the Award.
Who do I contact for help?
If you have additional questions, contact your OSP Contract Administrator.
Sponsor Specific Guidance
DOD – Stringent for some grants
DOD solicitations indicate whether or not to name key people in grant proposals. Please review the request for proposal for more information. Key people named in the proposal may also be named in the award – refer to the award document. Reductions in effort of 25% or more or substitutions of key personnel must be approved by the sponsor in advance. Awards are not flagged as PCK in KC.
For DOD grants:
- Policy Reference: For grants that incorporate OMB’s Uniform Guidance, the reference would be 2CFR 200.308 (c) (3).
For DOD contracts:
- Normally, DOD contracts include a clause that names specific individuals and describes the requirements for requesting sponsor approval for any change in key personnel.
NIH – Stringent for grants and contracts
Per NIH guidance, at the time of proposal, senior/key personnel are identified in the application. The NIH grant Policy Statement (GPS) defines senior/key personnel as:
The PD/PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant. Typically these individuals have doctoral or other professional degrees, although individuals at the masters or baccalaureate level may be considered senior/key personnel if their involvement meets this definition. Consultants and those with a postdoctoral role also may be considered senior/key personnel if they meet this definition. Senior/key personnel must devote measurable effort to the project whether or not salaries or compensation are requested. "Zero percent" effort or "as needed" are not acceptable levels of involvement for those designated as Senior/Key Personnel.
If awarded, those named at proposal stage must continue to track COI disclosures and training for as long as they are participating on the award. However, the prior approval requirement for changes in personnel effort of 25% or greater applies only to those senior/key personnel named in the Notice of Award (NoA). (See NIH GPS 184.108.40.206) Note, NIH program officials may identify certain senior/key personnel other than the PD/PI(s) in the NoA they consider critical to the project, i.e., their absence from the project would have a significant impact on the approved scope of the project. NIH points out that limiting the number of individuals named in the NoA does not diminish their scientific contribution; it only reduces the number of individuals subject to this requirement.
Policy reference: NIH Grants Policy Statement 220.127.116.11
NSF – Stringent
NSF uses the titles “Senior Personnel” and “Non Co-PI Senior Personnel”, for those responsible for the scientific/technical direction of the project and reporting. We must assume that both are “key personnel” for NSF projects. Note that on occasion, NSF may have additional solicitation-specific guidance for key personnel. Changes in effort of key personnel of 25% or more must receive prior approval from the sponsor. Key personnel are responsible for keeping current on COI disclosures for the life of the award.
NASA –Stringent for contracts but not grants
Grants: NASA policy strongly encourages one PI as the lead, only. Co-Investigators “serve under the direction of the PI”, so MIT does not require PI status approval for Co-I’s or others named, since they are all under the direction of the PI.
NASA does not use the term “Key Person” related to grants, however, several individuals may be named on the proposal and their participation must be verified through NSPIRES – this does not make them “key”.
Contracts: People named in the key personnel clause of the award are considered “key” for the award and must be tracked for effort purposes, but not for COI disclosures or training. NASA policy states that before removing, replacing, or diverting any of the listed or specified personnel or facilities, MIT must notify the sponsor “reasonably in advance” of the change, and submit a justification (including proposed substitutions) in sufficient detail for NASA to evaluate the impact on this contract.
Policy Reference: NASA FAR Supplement 1852.235-71
DOE - Stringent
“Senior key person” is referred to in the Funding Opportunity Announcement but not always defined, though we must assume that these are the same as “key personnel”. People named in the proposal as key personnel are considered “key” for the life of the project. Any changes in key personnel require DOE prior approval. Effort for key personnel must be tracked but COI disclosures or training are not required unless specified in the FOA.
NOAA typically only recognizes the PI as a key person. However, any person named in the proposal as key may also be named in the award. If named in the award as key, prior approval will be required to reduce their effort by 25% percent or more and/or to remove them from the project. A change in the project director or principal investigator shall always require approval unless waived by the agency.
Policy Reference: NOAA Administrative Standard Award Conditions
Foundation Sponsors with “key personnel” Policies
Key personnel are those named on the contact sheet, and who dedicate more than 25% of their time to the project. Reduction in effort of 25% or more or removal from the project must be approved by the sponsor in advance for named key people. The sponsor requires we track effort for key personnel but not COI disclosures or training.
Policy references: Simons Foundation Policies and Procedures
Related terms: Key Person, Key Persons