Management of Key Personnel

Key personnel play a crucial role in the success of any project,
being primarily responsible for its design, execution and reporting. At Case
Western Reserve University, key personnel encompass principal investigators
(PIs), co-PIs, and additional personnel identified by the PI due to their significant
role on the project.

PIs and co-PIs are people who contribute to the scientific development or execution of a project in a substantive way. Fellows on fellowship proposals are
mandatory inclusions as key personnel according to at CWRU.

Sponsor Requirements

• Sponsor-specific guidelines for tracking key personnel vary widely, necessitating careful attention.
• Most federal sponsors mandate tracking effort for key personnel and require notification of significant changes, such as a 25% reduction in effort or personnel departure.
• Some sponsors, including federal and foundation entities, stipulate ongoing compliance with conflict of interest disclosures and training for key personnel.

Management Responsibilities

• PIs and administrators bear the responsibility of tracking effort for key personnel and informing sponsors of significant changes.
• Requests for significant changes and those that require sponsor approval are submitted in writing to the Financial Compliance Office through SpartaGrants for review and approval. A CWRU institutional signatory will send CWRU approved and reviewed requests to the sponsor on behalf of the PI.  
• Notification to the financial compliance office is mandatory if planned reductions in key personnel's effort exceed 25% of their previously approved effort.

Sponsor-Specific Guidance

• Department of Defense (DOD): Stringent guidelines apply, requiring prior approval for changes in key personnel and adherence to OMB's Uniform Guidance 2 CFR 200.308 (c) (3).
• National Institutes of Health (NIH): Rigorous requirements extend to senior/key personnel identified in proposals and Notice of Awards (NOA), with particular emphasis on tracking effort and obtaining prior approval for significant changes.
  • Policy reference: NIH Grants Policy Statement 8.1.2.6
  • NIH Grants Policy Statement 8.1 1 Changes in Project and Budget
• National Science Foundation (NSF): Clear distinctions are made for senior personnel and non co-PI senior personnel, both of whom are considered key personnel. Prior approval is necessary for changes in effort exceeding 25%.
  •  Policy reference: NSF 17-1
• National Aeronautics and Space Administration (NASA): Policies vary for contracts and grants, with stringent guidelines for contract-related key personnel changes and flexible arrangements for grants.
  • Policy Reference: NASA FAR Supplement 1852.235-71
• Department of Energy (DOE): Regulations mandate prior approval for changes in key personnel, with effort tracking being compulsory.
  • Policy Reference: eCFR :: 10 CFR 603.125
• National Oceanic and Atmospheric Administration (NOAA): Primarily recognizes the PI as key personnel, although exceptions exist for other named individuals in proposals. Approval is required for significant changes in effort or personnel.
  • Policy Reference: NOAA Administrative Standard Award Conditions

Get in Touch

For detailed sponsor-specific guidance, please refer to the respective policy references provided. Should you have any questions or require further assistance, please don't hesitate to reach out to the Financial Compliance Office.

For questions about what goes into your proposal, contact our team.