Changing the Status of a PD/PI: Reminder of the NIH Prior Approval Policy

Have you wondered what happens when a program director/principal investigator (PD/PI) is no longer available to serve on an NIH grant? Maybe they have accepted a position at another institution? Or perhaps they are unable to carry out their duties for some other reason?

NIH recently issued a Guide Notice (NOT-OD-18-172) to remind the community about the NIH’s prior approval policy requirements when an institution seeks to change the status of a PI or other senior/key personnel as designated  in the Notice of  Award. This Notice also helps clarify the situations in which NIH’s prior approval is required.

NIH, for the most part, awards grants to institutions (see accompanying blog post). In the case of a PI getting a new position elsewhere, the recipient institution may seek NIH’s prior approval to relinquish the grant to the new employer, so the PI can continue to work on the project. Alternatively, the recipient institution could decide to keep the award and replace the PI with someone else who is qualified to take over the responsibilities of the original PI, as long as the NIH agrees. This is well within the rights of the recipient organization.

There are many scenarios where an institution could replace a PI or reduce a PI’s effort on an award with prior approval from NIH. Scenarios include, but are not limited to, situations where the PD/PI withdrew from the project, has been absent for at least three or more consecutive months, or the time the PI has available to dedicate to the project has reduced by 25 percent. Other scenarios may involve restrictions that the institution imposes on such individuals after the time of award, including but not limited to any restrictions on access to the institution or to the institution’s resources, or changes in the individuals’ (employment or leave) status at the institution.  In summary, prior approval is required any time there is a change in status of the PD/PI or other senior/key personnel designated on the award, where that change will impact his/her ability to carry out the approved research at the location of, and on behalf of, the recipient institution on the terms specified in the application and award.

You can learn more about the prior approval policy and requirements in the NIH Grants Policy Statement 8.1.2.6. If you have any further questions about the need for prior approval, contact the Grants Management Officer named in your Notice of Award.