Key Person Maintenance
Key Person Maintenance in the Award in KC is now performed by RAS (not by the PI or Department Administrator(s)).
Why do we need to track key persons?
The PHS regulations apply to all Investigators. Under the regulation, the term “Investigator” is defined as the Principal Investigator, Co-Principal Investigator, and any other individuals who are independently responsible for the design, conduct, or reporting of PHS funded research; these individuals may be referred to as “Key Personnel.”
Each PI is responsible for identifying the Investigators (or “Key Personnel”) on a project. While an academic or Institute title alone cannot determine who is an Investigator for purposes of the PHS regulations, postdoctoral associates and graduate students would rarely be considered independently responsible for a project. Careful consideration should be given on listing Key Person(s) on a proposal – RAS has created some additional guidance to help you determine whether or not individuals are likely to be categorized as Investigators.
How will we track key persons?
The Kuali Coeus (KC) system provides key person maintenance functionality to track individuals deemed Investigators or Key Person(s). If individuals were originally listed on the development proposal in KC, the information is carried through to the Award and verified by RAS per the Sponsor award received. The KC system then checks that COI and training requirements have been met. If Key Person(s) should be deleted or added to the Award, please send the request to your RAS Contract Administrator for further review.
Remember – if you are reducing the effort of key persons named in a Notice of Award by 25% or more of their current effort, you must write to your program officer and request prior approval of the reduction (your RAS Contract Administrator should receive a copy of this request as well). Any other reduction in effort may be reported in your next progress report.
Who can maintain key persons?
RAS staff are the only personnel to maintain key persons in an Award in the KC system. If Key Person(s) should be deleted or added to an Award, please contact your RAS Contract Administrator for further review.
Who do I contact for help?
If you have additional questions, contact your Contract Administrator.