Key Personnel

Key personnel are those people, including PIs and Co-PIs, who are essential to carrying out the work of a project, typically those responsible for the design, conduct and reporting of the research. 

Identifying Key Personnel

MIT requires that PIs and Co-PIs, as well as fellows on any fellowship proposal, must be included as key personnel.

PIs are discouraged from listing additional project participants as key personnel, since key personnel must meet additional requirements, depending on the sponsor.

Expectations for Key Personnel

Key personnel must certify proposals in KC. Outside MIT, requirements for key personnel vary by sponsor, but often include:

  • Disclosures
  • Prior sponsor notice and approval for changes in effort (especially decreasing effort)
  • PI/DLCI tracking of effort

  • For federal sponsors, tracking key personnel varies depending on the agency. Federal sponsors minimally require:

    • Effort tracking for key personnel
    • Sponsor notification and/or approval with significant reduction in effort (25% or more)
    • Sponsor notification if key personnel leave the project
    • Notice to sponsor of new key personnel

  • Non-federal requirements will vary by sponsor and funding mechanism. Review the sponsor requirements around key personnel and the NOA for sponsor-designated key personnel. Adhere to award tracking requirements and submit change requests requiring sponsor prior approval to RAS for review prior to submitting to the sponsor.

Proposal Stage

All key personnel must be included in the proposal before it is routed to RAS. PIs and Co-PIs must certify the proposal, and additional key personnel may need to certify depending on the sponsor or solicitation:

  • NIH/PHS proposals: Follow instructions on Investigators and Key Persons Certifications NIH/PHS Sponsor Proposals [PDF]
  • Non-NIH/PHS proposals: If a non-NIH/PHS solicitation or sponsor requires key personnel (aside from PIs and Co-PIs) to certify, the Aggregator should check the "PCK" flag in KC: Certifying Key Persons and Fellows [PDF]
  • Fellowship proposals: Most fellowships require the faculty mentor to be the named PI and the graduate or postdoctoral fellow to be named in the role of Key Person. The Aggregator must check the "PCK" flag in the Supplemental Information section. 

Award Stage

At award, review the Notice of Award for named key personnel:

  • Contact your RAS CA to update the list of key personnel in KC.
  • Ensure all listed key personnel meet sponsor requirements. If sponsor requirements are not met, the account will remain in hold status. 

Managing Key Personnel for the Life of the Award 

PIs and DLCIs are responsible for tracking effort for key personnel.

No changes may be made to the key personnel on a project before review by your RAS CA. After RAS reviews a requested change, they can advise on sending it to the sponsor, and update the key personnel listed in KC when appropriate.

Request RAS review (before requesting approval from sponsor) if:

  • Key personnel reduce their effort. 
  • Key personnel leave the Institute.
  • Key personnel take a leave of absence.
  • New key personnel are added to the award. If approved, new key personnel will need to certify the proposal.

When writing to your RAS CA for review, provide any relevant correspondence between the PI and the sponsor and plan to discuss any cost-sharing affected by the change.

Sponsor-Specific Guidance

  • DOD solicitations indicate whether or not to name key people in grant proposals. Please review the request for proposal for more information. Key people named in the proposal may also be named in the award – refer to the award document. Reductions in effort of 25% or more or substitutions of key personnel must be approved by the sponsor in advance. Awards are not flagged as PCK in KC.

    For DOD grants:

    • Policy Reference: For grants that incorporate OMB’s Uniform Guidance, the reference would be 2CFR 200.308 (c) (3).

    For DOD contracts:

    • Normally, DOD contracts include a clause that names specific individuals and describes the requirements for requesting sponsor approval for any change in key personnel.

  • “Senior key person” is referred to in the Funding Opportunity Announcement but not always defined, though we must assume that these are the same as “key personnel”. People named in the proposal as key personnel are considered “key” for the life of the project. Any changes in key personnel require DOE prior approval. Effort for key personnel must be tracked but COI disclosures or training are not required unless specified in the FOA.

    Policy Reference: DOE Assistance Regulations, 2 CFR Part 200 as amended by 2 CFR Part 910 at http://www.eCFR.gov [website]

  • Grants: NASA policy strongly encourages one PI as the lead, only. Co-Investigators “serve under the direction of the PI”, so MIT does not require PI status approval for Co-I’s or others named, since they are all under the direction of the PI.

    NASA does not use the term “Key Person” related to grants, however, several individuals may be named on the proposal and their participation must be verified through NSPIRES – this does not make them “key”.

    Contracts: People named in the key personnel clause of the award are considered “key” for the award and must be tracked for effort purposes, but not for COI disclosures or training. NASA policy states that before removing, replacing, or diverting any of the listed or specified personnel or facilities, MIT must notify the sponsor “reasonably in advance” of the change, and submit a justification (including proposed substitutions) in sufficient detail for NASA to evaluate the impact on this contract.

    Policy Reference: NASA FAR Supplement 1852.235-71 [website]

  • Per NIH guidance, at the time of proposal, senior/key personnel are identified in the application. The NIH grant Policy Statement (GPS) defines senior/key personnel as:

    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. Typically these individuals have doctoral or other professional degrees, although individuals at the masters or baccalaureate level may be considered senior/key personnel if their involvement meets this definition. Consultants and those with a postdoctoral role also may be considered senior/key personnel if they meet this definition. Senior/key personnel must devote measurable effort to the project whether or not salaries or compensation are requested. "Zero percent" effort or "as needed" are not acceptable levels of involvement for those designated as Senior/Key Personnel.

    If awarded, those named at proposal stage must continue to track COI disclosures and training for as long as they are participating on the award. However, the prior approval requirement for changes in personnel effort of 25% or greater applies only to those senior/key personnel named in the Notice of Award (NoA). (See NIH GPS 8.1.2.6) Note, NIH program officials may identify certain senior/key personnel other than the PD/PI(s) in the NoA they consider critical to the project, i.e., their absence from the project would have a significant impact on the approved scope of the project. NIH points out that limiting the number of individuals named in the NoA does not diminish their scientific contribution; it only reduces the number of individuals subject to this requirement.

    Policy reference: NIH Grants Policy Statement 8.1.2.6 [website]

  • NOAA typically only recognizes the PI as a key person. However, any person named in the proposal as key may also be named in the award. If named in the award as key, prior approval will be required to reduce their effort by 25% percent or more and/or to remove them from the project. A change in the project director or principal investigator shall always require approval unless waived by the agency.

    Policy Reference: NOAA Administrative Standard Award Conditions [website]