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I. Scope 

This is a whole university policy.  It applies to all members of the Â鶹Æƽâ°æ (the “university”) community, including all employees, faculty affiliates, and retired faculty.  

II. Purpose & Policy Statement 

Externally funded research is performed across the university by a variety of personnel in academic and non-academic units. This policy addresses who may serve as a principal investigator or co-principal investigator on externally funded research. 

III. Definitions 

Principal Investigator (PI) means the individual responsible for activities on a research project or activity, particularly those funded by a grant, a cooperative agreement, a training or public service project, a contract, or other sponsored mechanism. Responsibilities include the intellectual conduct of the project, fiscal accountability, administration, and compliance. It is possible that the PI may share these responsibilities with a multi-investigator team. 

Co-Principal Investigator (co-PI) means a senior member of the key personnel team who shares administrative, fiscal, and scientific accountability with the PI on research projects. The Co-PI can be named in the proposal and on project documentation as a co-PI provided this role is accepted by the sponsor.  

For the purposes of this policy, the unit leader is defined as the most senior institutional official of a unit (in the following, “unit leader”). For academic units, this is the Dean. For units within the Office of Research, this is the Vice Provost for Research. For other organizations, this may be an Associate Provost, Vice President, or similar institutional role. 

IV. Policy

A. Eligibility to Serve as a Principal Investigator of Co-Principal Investigator 

Tenured and Tenure-Eligible (TTE) Faculty. TTE faculty may serve as principal investigators (PI) or co-principal investigators (co-PI) on external grants and contracts. 

Non-Tenure Eligible Faculty. NTE faculty with appointments including research responsibilities may serve as PIs and co-PIs on external grants and contracts. NTE faculty without explicit research responsibilities may serve as PIs and co-PIs with approval from their unit leader. 

Professional Faculty. Professional faculty with research responsibilities may serve as PIs and co-PIs on external grants and contracts with approval from their unit leader. 

Staff. Staff members with research responsibilities may serve as PIs and co-PIs on external grants and contracts with approval from their unit leader. 

Post-doctoral Fellows. Post-doctoral fellows may serve as PIs and co-PIs with approval from their mentors, department head or center director, and unit leader. 

Retired Faculty. A retired faculty member may not return to work at the university in any capacity, whether compensated or not, until at least 26 weeks have passed since the date of retirement. (See Employment After State Service for Commonwealth of Virginia policy.)  

After the relevant break in service, retired faculty members may resume work on externally funded research, but they may not continue as PIs or co-PIs. Continuing awards must be transitioned to other university faculty or staff who are eligible to be a PI or co-PI. Retired faculty can serve as senior or key personnel on externally funded projects. Grants that include retired faculty should have facilities and administrative (F&A) costs budgeted to cover administrative costs associated with their participation, as allowable by the funding sponsor. 

Faculty Affiliates. Faculty affiliates may not serve as a PI or co-PI on external grants.

B. Implementation

This policy provides the minimum requirements for the university. Deans and other unit leaders supervising personnel involved in externally funded research may implement more restrictive requirements through school, college, and unit policies. 

For any faculty, staff, or post-doctoral fellow whose service as PI or co-PI requires approval from their unit leader, a memo describing the approval and their specific roles and responsibilities must be provided by the unit leader’s office to the director of the appropriate Office of Sponsored Programs. 

V.  PROCEDURES FOR RETIRED FACULTY MEMBERS WORKING ON EXTERNALLY FUNDED RESEARCH

This section will be superseded once the Faculty Retirement and Return to Work Policy (last updated in April 2019) is revised, at which point the Faculty Retirement and Return to Work Policy will govern. 

A. Break in Active Work 

A retired faculty member may not return to work at the university in any capacity, whether compensated or not, until at least 26 weeks have passed since the date of retirement. (See Employment After State Service for Commonwealth of Virginia policy.) 

B. Externally Funded Projects

After the required 26-week break in service, retired faculty may participate in externally funded projects under the following conditions. 

• A retired faculty member may continue to work on externally funded research, but they may not continue as PI or co-PI. Continuing awards must be transitioned to a university employee who meets the conditions in Section IV(A). Retired faculty can serve as senior or key personnel on the project.
• If the retired faculty member will be paid:
  • The compensation must meet the Fair Labor Standards Act (FLSA) exempt status as advised by Human Resources (currently minimally $684 per week) for the duration of the project.
  • Compensation for the retired faculty member is based on their expertise and their pre-retirement salary.
  • Funding agency approval of both the number of hours and the compensation rate for the retired faculty investigator is required and must be coordinated through the appropriate Office of Sponsored Programs. 
  • Total hours compensated annually may not exceed 1,500 hours to be in compliance with the Affordable Care Act (ACA).
  • The retired faculty investigator must be re-employed in a part-time professional staff position (non-benefit eligible) or adjunct faculty (non-benefit eligible), at the discretion of the school, college, or unit, following University Human Resources (UHR) procedures. The position must be created by the sponsoring home unit using the UHR recruitment system, following the processes required for targeted hires per the terms of the grant.
  • All relevant re-employment steps and procedures must be followed, which may include a system application, background check, completion of an I-9, and required training.
  • The retired faculty investigator will be paid semi-monthly on the standard university salary schedule for the duration of funding, to be monitored by the responsible home unit. 

VI. Authority and Amendments

This policy was approved the Provost on September 14, 2026.  
The Vice Provost for Research is responsible for the interpretation and enforcement of this policy and is permitted to make minor and technical amendments.   

 VII. Related Policies and Documents