The Harvard T.H. Chan School of Public Health faculty have a range of appointment and employment arrangements as a result of the extent of our collaborations across Harvard and affiliated institutions. These circumstances require that we make decisions about PI status on grant submissions. The purpose of this policy is to articulate the Harvard Chan School’s determination of appointees’ eligibility to serve as PI on grants submitted through the Harvard Chan School.
Please contact pieligibility@hsph.harvard.edu with questions about eligibility and/or waivers. The Waiver Review Committee meets the third Thursday of each month. Completed and signed waivers must be submitted to pieligibility@hsph.harvard.edu two weeks before the monthly meetings to be considered.
Policy Documents and Resources
For questions about the policy or eligibility status, please contact pieligibility@hsph.harvard.edu.
Eligibility Status Table
| Eligible Appointments |
Waiver Required |
Faculty and Research appointment types employed at the Harvard Chan School with at least 25% FTE:
-
- Primary ladder and non-ladder faculty* (all ranks)
- Secondary faculty (all ranks)
- Research Scientists (all ranks)
- Research Associates / Postdocs / Students**
|
Faculty and Researchers with the following appointment types and those not employed at the Harvard Chan School:
-
- Secondary Faculty with Unpaid Appointments
- Adjunct Faculty
- Visiting Faculty / Scientists
- Instructors
- Research Associates / Postdocs submitting independent research awards
|
*Ladder: Assistant, Associate, Full Professor; Non-ladder: Lecturer, Senior Lecturer, Professor of Practice, Professor in Residence
**Students, Postdoctoral Fellows, and Research Associates are eligible to apply for fellowship, career development, and mentored training grants
PI Eligibility FAQs
Why was the PI eligibility policy changed?
The major objectives of the revisions were to target School/Departmental resources to proposals that are mission-central and to ensure that we are preserving resources for faculty and other academic appointees who are central to our School’s operation. The policy updates will enable the School to focus its time and resources on these faculty and alleviate past issues including effort reporting and compliance.
How do I submit a waiver?
The waiver form is available on this webpage, linked above. Once the form has been submitted, it will be routed to the individuals you identify in the form as approvers for signature. The committee meets on the third Thursday of each month, and waivers should be completed and signed at least two weeks prior to the monthly meeting. Waivers not received at least two weeks prior to the meeting are not guaranteed review in that month.
How much time should I allow for waiver review?
Completed and signed waivers should be submitted two weeks prior to the monthly committee meeting. Please allow at least two additional weeks after the meeting to address any follow-up questions the committee may have before making an eligibility decision. It is recommended to complete this waiver process at least two months ahead of internal grant deadlines to ensure that PI eligibility is confirmed before significant work is done to prepare the proposal.
Who reviews waivers?
The PI Eligibility Committee reviews waivers. The committee is comprised of representatives from ORSD, SPA, and OFA.
What is the waiver decision criteria?
Decision criteria include mission criticality, the role of the School, budget, appointment/grant period alignment, department infrastructure, and sponsor/funder track record.
Does the PI eligibility policy apply to data use agreements (DUAs) and research computing?
Yes, the PI eligibility policy generally applies to both processes. More information is forthcoming about the application to DUAs (information on the DUA process is available here). Information on FASRC and eligibility can be found here.
What is the difference between the HSPH PI eligibility policy and the IRB PI eligibility policy?
The IRB policy applies to both HSPH and HMS. The table above/below highlights the differences between the two.
|
Eligible Appointments
|
Waiver Required
|
Extramural Research Grants, Data Use Agreements, and Research Computing Requests
|
Faculty and Research appointment types employed at the Harvard Chan School with at least 25% FTE:
- Primary ladder and non-ladder faculty* (all ranks)
- Secondary faculty (all ranks)
- Research Scientists (all ranks)
- Research Associates / Postdocs / Students**
|
Faculty and Researchers with the following appointment types and those not employed at the Harvard Chan School:
- Secondary Faculty with Unpaid Appointments
- Adjunct Faculty
- Visiting Faculty / Scientists
- Instructors
- Research Associates / Postdocs submitting independent research awards
|
IRB
|
A Principal Investigator (PI) for non-exempt Human Research must be a Harvard LMA School faculty member (e.g., professor, associate professor, assistant professor, instructor, lecturer, PI-eligible research scientist).
Any Harvard affiliate (e.g. faculty, staff, or student) may serve as a PI for Not Human Subjects Research and Exempt research.
More details on the IRB’s PI Eligibility policy can be found in the ORARC Investigator Manual. |
The IRB may grant an exception to the PI eligibility requirement. If determined to be appropriate, such exceptions are made on a protocol-by-protocol basis.
To request a PI Exception, FORM: PI Exception Request must be submitted with the IRB application (HarvardKey log in required to access the form).
Have questions about your candidacy as an Exception PI, IRB policy and forms, or other questions? Please contact Kim Serpico, Assoc. Director of IRB Operations (kserpico@hsph.harvard.edu)
|
*Ladder: Assistant, Associate, Full Professor; Non-ladder: Lecturer, Senior Lecturer, Professor of Practice, Professor in Residence
**Students, Postdoctoral Fellows, and Research Associates are eligible to apply for fellowship, career development, and mentored training grants
Does the PI eligibility policy apply to career development awards/fellowships?
The PI eligibility policy applies only to research grants. Postdocs and Research Associates are eligible without a waiver to apply for career development awards and fellowships, but will require a waiver when applying as a PI for an independent research award.
How do I know if it is a career development/fellowship award?
At the NIH, K series awards are career development and F series are fellowships. For non-federal awards, if a mentor is required for the project, it is typically a career development award. Please reach out to pieligibility@hsph.harvard.edu with questions about specific awards.
If an individual in the “waiver required” category is applying as a Co-PI, rather than as the sole PI, do they still need to submit a waiver?
Yes.
If an individual in the “waiver required” category is a sub and listed as PI, do they still need a waiver?
Yes.
If an individual in the “waiver required” category is listed as the core or project lead on a project or core within a larger center, do they need a waiver?
As long as they are not named the PI of the overall center, they do not need a waiver to be a lead on a core. The policy applies only to those individuals listed as PD/PI of the overall grant application or subcontract.
If an individual in the “waiver required” category is listed as a Co-I, do they need a waiver?
As long as the individual is a Co-I and not a Co-PI, they do not need a waiver.
