PI Changes in Affiliation and Absences from a Sponsored Project
The following guidance is provided to assist principal investigators (PIs) and departments take the proper steps when a PI’s relationship to UC Berkeley changes and/or when a PI must be absent from a sponsored project temporarily or for a longer period of time.
When a PI plans to move to a another institution and to dissolve his or her affiliation with UC Berkeley, the PI will need to either terminate their active sponsored projects or transfer (with the sponsor’s approval) these projects to their new institution.
The PI will need to follow the sponsor’s specific guidelines for terminating or transferring his or her sponsored projects. The first step is always to contact SPO. SPO will provide guidance on each sponsor’s requirements for terminating or transferring a project. This usually involves special paperwork and institutional approvals. SPO also will ensure that the University’s policies are followed. Typically, such actions require the combined efforts of the PI, the sponsor’s representative, the PI’s department, SPO, Contracts and Grants Accounting, and, when transferring a sponsored project, contract and grants personnel from the PI’s new institution.
If the PI is going to take a leave of absence from UC Berkeley but will retain his or her UC Berkeley PI status, the PI may choose to continue to manage their active sponsored projects through UC Berkeley as long as the PI will be able to successfully supervise the projects and be actively involved from a remote location. PIs should consult with SPO if such a leave will impact the PI’s level of effort on the project. See Reduction in PI/Co-PI Effort for additional guidance on changes in PI effort.
When a PI is going to be “absent” from their sponsored projects, i.e., not able to manage the projects even from a remote location, the PI will need to follow the sponsor’s guidelines about reporting and managing the absence.
NSF has very specific guidance on this. For a short term absence (less than three months), SPO is required to notify NSF as soon as SPO is aware of the absence and provide a plan for managing the project during this short period of time. For a longer period of absence (more than three months), SPO must notify NSF, provide a plan for managing the project during the PI’s absence and obtain NSF approval of the plan. If a PI plans to be absent from an NSF project, please contact SPO as soon as possible and provide the beginning and ending dates of the period of absence and a description of the how the project will be managed during the PI’s absence.
Substitute PI Option
If the PI is going to be absent from the project and wishes to appoint a substitute PI to manage the project during the original PI’s absence, SPO must obtain the approval of the new PI from the sponsor. SPO must also obtain internal approval from the Chair/Dean/Director of the original PI’s department/unit as well as the Chair/Dean/Director of the substitute PI’s department/unit, if different from that of the original PI.
Obtaining Sponsor Approval
The original PI should draft a letter to the program officer seeking approval for a substitute PI. (The substitute PI should have no reportable conflicts of interest relative to the project.)
The letter should:
- Describe the reason for the original PI’s absence from the project and the need to continue the project under the direction of a substitute PI.
- Include information about the new PI’s background, qualifications, available facilities, and ability and willingness to manage the project through the anticipated absence end date.
- Include the following certification statement from the substitute PI:
Substitute PI Certification: I am not debarred, suspended, or proposed for debarment or suspension by any agency of the U.S. Government, and I agree to accept the role of PI and the responsibility for the scientific conduct and financial oversight of the project entitled, (insert title of project). I agree to provide all reports required by the sponsor according to the timelines specified in the award.
- Provide the signatures of the original PI as well as the substitute PI at the bottom of the letter.
Obtaining Internal Approval
The Chair/Dean/Director of the original PI’s unit should then send SPO an email message stating the following:
I approve the transfer of PI status for the project entitled (insert title of project) awarded to UC Berkeley by (insert name of sponsor) from (insert name of original PI) to (insert name of substitute PI).
If the substitute PI is from a different academic or research unit, the Chair/Dean/Director of the substitute PI’s unit should send SPO an email message stating the following:
As the individual responsible for (insert substitute PI’s academic/research unit), I approve the transfer of the responsibility of the project entitled, “(insert title of project),” to my unit under the supervision of (insert name of substitute PI). My unit accepts responsibility for the conduct and administrative oversight of the project.
After these approvals are obtained, SPO will request all required conflict of interest forms from the substitute PI and endorse and submit the letter to the sponsor on behalf of the University. (For NSF, this will be through FastLane.)
In such cases PIs should be aware that there is no guarantee that sponsor approval will be forthcoming.