Who is eligible to be a Principal Investigator?
The basis for determining who is eligible to be a Principal Investigator (PI) is grounded in who may receive funds through a grant, contract, or other funding mechanism on behalf of the University.
Who may be listed on an IRB application follows these same guidelines however there are some exceptions. Those who are not PI eligible may still serve as a PI on an IRB application however there must also be a faculty sponsor listed. This is particularly true when the PI on the IRB application is a student.
PI eligibility is generally delegated to the Schools who have developed eligibility criteria for their faculty as well as specific procedures for granting exceptions to their criteria. Below you will find policies relevant to who may serve as a PI as well as the process to grant an exception to these policies.
Faculty of Arts and Sciences (FAS)
According to FAS policy, only teaching members of the Faculty and a select number of other academic appointees are considered to be PI eligible. The policy, including a list of who is eligible may be found here
The FAS has also established a process by which “Harvard appointees who are not otherwise PI-eligible may on occasion be authorized to serve as PI with approval by the appropriate Divisional Dean. The department chair or center director can submit such requests using the PI Rights Questionnaire form, and the justification must be compelling.”
Generally, only those who have an academic appointment may be considered PI eligible. However, there may be circumstances when individuals that do not have an academic appointment who report to the University Central Administrative Unit may have the opportunity to seek external funding for special projects that contribute towards the goals or the mission of the individual’s unit. The Office of the Provost for Central Administration has developed a process for such circumstances. The policy for this process may be found here. The Request Form to use with this process may be found here.
The Harvard Graduate Schools have incorporated different policies and procedures for determining PI eligibility. Some schools maintain a list of names of those that are eligible while others create policies according to faculty rank or title. Given the variability, it is recommended that researchers check in with their respective school.
Undergraduate students, Graduate Students, and Post-Doc’s
As previously mentioned, those that are affiliated with Harvard University Area, including undergraduate students, graduate students, or post-doctoral researchers, are permitted to be a PI on an IRB application however this designation is only valid if a PI eligible Faculty Sponsor is also listed on the IRB application.
What does it mean to be a Faculty Sponsor?
A Faculty Sponsor sponsors the PI who is listed on the IRB application and confirms that they will oversee the research and ensure that the PI complies with all IRB requirements. For more information on what it means to be a faculty sponsor, please see the Ancillary Review Reference document.
What if my Faculty Sponsor is not PI eligible?
There may be times when the best person to oversee a student’s research is not considered PI eligible. For example, faculty classified as lecturers, or similar titles, may serve as senior thesis advisors however they are ineligible to be named as a faculty sponsor on a student project as they are not considered PI eligible.
The FAS has “established a guideline that establishes a process for waiver for a particular lecturer, or other faculty appointment holder, to be PI eligible for the limited purpose of serving as a faculty sponsor for undergraduate student human subject research protocol submissions.” Please see the policy as well as the Waiver of PI Status for Human Subject Research Request Form for more information.