If individuals are named in an NIH Notice of Grant Award when it is initially received, but not named in the NOAs for following incremental years, are they still Key Persons?
Yes. They must still be treated as named key persons and prior approval from NIH is required before removing them as Key Persons on the award.
If the NOA simply says change in “Key Persons” needs approval, do you have to go to NIH for approval?
Only if the Key Person is actually named in the award would approval be required per NIH policy.
In the NIH Progress Report, does listing someone by name in the “all personnel report” mean that person has been identified as a key person and will be subject to the regulations regarding training and COI disclosure?
No. Only if you identify an individual specifically as a Key Person in a progress report or a proposal will they be subject to the regulation requirements.
How should Subrecipient PIs/Consortium PI’s etc be entered in proposals?
They should be entered as Key Persons with the role “Subaward Investigator” in order for Coeus to handle them correctly and not require certification or COI (which should be handled at their own institution).
If you are deleting a Key Person from an award in Kuali Coeus, do you have to go to NIH for approval?
Not if the person is not named in the award notice from NIH. You would, however, still need to include the change to key persons in the Progress Report with NIH.
Who can maintain key persons?
PI’s will automatically have access (with their MIT certificate) to maintain the Key Persons on their awards in Kuali Coeus My Awards. Upon entering My Awards (coeus.mit.edu), an Investigator will see a list of their awards.
In addition to the Principal Investigator, OSP can also assign the role of “key person maintainer” to a department administrator to maintain this information. This role will allow an administrator to edit the key person information for all awards in their unit.
To request this authorization, an Administrative Officer or Fiscal Officer must send a request to firstname.lastname@example.org. Please include the name and email address for each individual as well as the unit(s) for which they should have the role assigned.
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; Unfortunately, OSP was not able create that role for the initial implementation but will do so in the future if it becomes problematic.