Identifying PHS Investigators


Based on the PHS/NIH definitions below, all individuals listed as “senior/key personnel” on a PHS funded proposal, award, or a project sponsored by an entity following PHS regulations are considered “Investigators.” Therefore, all senior/key personnel must submit Annual Disclosures (KR COI) and complete COI training as required by the PHS regulations.

Please note the definition of Investigator is broader than the definition of senior/key personnel so there may be investigators on the project who are not senior/key personnel.  For any non-UCI Investigators on the UCI proposal/award and any subrecipients following UCI's PHS COI policy, all individuals who meet the definition of an Investigator must complete the Form 800SR.

The project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants.

Senior/Key Personnel (NIH Glossary)
The PD/PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant. "Zero percent" effort or "as needed" is not an acceptable level of involvement for senior/key personnel. 

The PHS/NIH Application Guide allows PIs to also include Other Significant Contributors in their senior/key personnel section.  Based on the definition of an Other Significant Contributor listed below, these individuals (when appropriately classified) do not meet the definition of an Investigator.  Therefore, they are not required to submit financial disclosures or complete the COI training.

Other Significant Contributor (OSC) (NIH Glossary)
Individuals who commit to contribute to the scientific development or execution of the project, but do not contribute any specified measurable effort (i.e., person months) to the project.  These individiuals are typically presented at effort of "zero person months" or "as needed."  Individuals with measurable effort may not be listed as Other Significant Contributors (OSCs). Consultants should be included if they meet this definition.  To identify an individual as an OSC in the Senior/Key Person section, please select "Other" for the Project Role and type "Other Significant Contributor" for the Other Project Role Category.  

Principal Investigators should carefully consider how they classify the individuals involved in their study based on the PHS definitions, due to the different requirements and implications. The Principal Investigator is responsible for accurately and appropriately classifying the individuals on their project based on their responsibilities, and collecting financial disclosures from all project participants that meet the definition of “Investigator.”



For Non-UCI Investigators following UCI's PHS COI Policy:

  • Subrecipient/Non-UCI Investigator Disclosure (Form 800SR)
  • Addendum for Non-UCI Personnel (Form COI-3)

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