Senior/Key Personnel are those individuals identified in the grant application, progress report, or any other report submitted to the PHS. Program Director/Principal Investigatgors (PD/PIs)are always considered senior/key personnel and are always named in the Notice of Award (NoA). NIH program officials use discretion in identifying in the NoA senior/key personnel other than the PD/PI(s), and may identify individuals that are considered critical to the project, i.e., their absence from the project would have a significant impact on the approved scope of the project.
Change in status, including absence, of PD/PI and other senior/key personnel named in the NoA requires prior approval from NIH. Change in status is defined as withdrawal from the project, absence from the project for any continuous period of three months or more, or reduction of time devoted to the project by 25 percent or more from the level that was approved at the time of initial competing year award. For example, a proposed change from 2 calendar months effort to 1.5 calendar or fewer months effort would require prior approval.
Change in status for senior/key personnel named in the proposal but not named in the NOA, does not require prior approval but must be reported in the annual progress report.
Limiting the number of individuals that are named in the NoA does not diminish the scientific contribution to the project of the senior/key personnel not named in the NoA; it does reduce the number of individuals subject to the prior approval requirement.
Requesting Prior Approval
NIH must approve any alternate arrangement proposed by the grantee, including any replacement of the PD/PI or senior/key personnel named in the NoA, and the addition of any new PD/PIs.
The request for approval of any additional or substitute PD/PIs or Senior/Key Personnel named in the NoA must be accompanied by a strong scientific justification related to the project, including any proposed changes in scope, the biographical sketch of any new individuals proposed and other sources of support, and any budget changes resulting from the proposed change. The Commons ID must be provided for any new PD/PIs.
If the arrangements proposed by the grantee, including the qualifications of any proposed replacement, are not acceptable to the NIH awarding IC, the grant may be suspended or terminated. If the grantee wishes to terminate the project because it cannot make suitable alternate arrangements, it must notify the GMO, in writing, of its wish to terminate, and NIH will forward closeout instructions.
The requirement to obtain NIH prior approval for a change in status pertains only to those personnel NIH designates in the NoA regardless of whether the applicant organization designates others as senior/key personnel for its own purposes.