Research Management Group (RMG)

Stanford PI Eligibility and Waiver Policy Guidelines



Special Announcement

Clinician Educator (Faculty)
Multi-site Clinical Trial CE PI waiver >>
Practice of Medicine CE PI waiver >>



Who has Principal Investigatorship (PI) Eligibility?

Principal Investigatorship (PI) Eligibility and Criteria for Exceptions (Research Policy Handbook RPH 2.4>>)
Per this policy, eligibility to act as a principal investigator (PI) or co-principal investigator (Co-PI) on externally-funded projects is a privilege limited to members of the Academic Council and to the MCL faculty.   This policy limitation is in place because principal investigators are responsible for determining the intellectual direction of the research and scholarship, and for the training of graduate students.




Obtaining PI Waivers for those who do not have PI eligibility


The designation of "PI" or "Co-PI" for any member of the Academic Staff, or other individual who is not a member of the University's Academic Council or MCL faculty, requires specific approval by the relevant department chair, school dean and, in some cases, the Dean of Research, by obtaining PI Waivers as described under PI Waiver Exception Types. See the table below for position types and whether or not they can submit PI waiver requests.

Who can submit PI waiver requests?
-See matrix below >>



Other Designations

Who can be Associate Investigators?
The following individiuals can be "Associate Investigators" on sponsored projects: Members of the Academic Staff-Teaching (AS-T, Lecturers and Sr. Lecturers) ; Academic Staff-Research (AS-R, Research Associate); Senior Research Scientists
Who can be Co-Investigators?
Senior members of the Academic Staff-Research also may be designated by their Academic Council or MCL faculty supervisors as "Co-Investigators" on those externally-funded projects in which the senior AS-R members carry substantial roles.



Matrix: Who can submit requests for PI waivers?

  Type of PositionPI Waiver Exception Types*
  Eligible for a PI waiver? Pilot PI Waiver Program Career Development Clinician Educator Conferences and
Workshops
Early PI ship Inter-disciplinary Project
Faculty with acting appointments
Yes         checkbox  
Clinical Educator Line Faculty

There are two CE PI waiver categories:
-Multi-site Clinical Trial CE PI waiver
-Practice of Medicine CE PI waiver


Yes     checkbox      
Clinical Instructors
(Per Stanford PIship policy, Clinical Instructors cannot be PIs for external sponsored projects)

No            
Clinical / medical fellows Yes checkbox checkbox        
Instructors
(Only Instructors with M.D. or M.D. / Ph.D. degrees are eligible for the Pilot PI waiver program)

Yes checkbox checkbox        
Postdoctoral Fellows  
(PI waivers not needed for Fellowships; but for Fellowships which are career development grants. Only Postdocs with M.D. and M.D. / Ph.D. degrees are eligible for the Pilot PI waiver program)
Yes checkbox checkbox   checkbox   checkbox
Academic Staff-Research: Research Associate;
Senior Research Scientists; Senior Research Scholars
Yes   checkbox   checkbox   checkbox







































*See the Rare Exception PI waiver category for those that do not fll within eligibility referenced above.



A.   Exceptions Subject to the Approval of the Department Chair and School


1.   EARLY PI-SHIP

Early pi-ship pi waiver


Faculty appointment must be pending. Long form must be submitted and accepted by the School of Medicine Dean's Office. Your RPM will confirm with Rebecca Robinson in Academic Affairs, regarding the appointment status. An award cannot be accepted until the faculty appointment has been confirmed.
See the PI waiver Memo guideline checklists and templates below>>

2.  CONFERENCES/WORKSHOPS

conference/workshop pi waiver


May serve as PI on externally-sponsored projects whose sole purpose is to fund short conferences, exhibits, workshops, or other public events of a character appropriate to the University.
PI waiver Memo guideline checklists and templates below>>


3.   CAREER DEVELOPMENT AWARD

career development pi waiver


Awards whose stated purpose is to advance the individual's scientific career.  The project must be carried out under the mentorship of an established faculty investigator who is named in the proposal, and must be conducted within the overall intellectual scope and laboratory space of the faculty advisor [School of Medicine].   (Note: a photocopy of the eligiblity requirements of the non-governmental sponsor's RFP must be attached to the PI Waiver Memo to confirm that the funding opportunity is indeed a career development award. )



4.   PART OF LARGE INTERDISCIPLINARY PROJECT

large interdisciplinary project pi waiver


Projects within the scope of a large interdisciplinary program defined as:


All of the following conditions must be met in order for the department chair and school dean to approve PI exceptions in cases:




B.    Rare Exceptions Subject to the Approval of the Department Chair, School Dean, and University Dean of Research Office


rare exception PI waiver


All other situations not listed above.  Please see the Research Policy Handbook PI Wiaver Guidelines (RPH 2.4).  Waivers requiring University approval may be approved at the discretion of the Dean of Research in unusual and non-recurring situations that meet a particular need or opportunity for the University.  Waivers under these situations, however, will rarely be granted.




C.   Clinician Educator (Faculty) Waivers to serve as Principal Investigator 

     


C.1  Multi-Site Clinical Trial Clinician Educator
( Faculty) Waiver to serve as Principal Investigator:


Criteria:
  

    1. Must hold rank of Clinical Assistant Professor, Clinical Associate Professor, or Clinical Professor. 
    2. Clinical Instructors are not eligible.
    3. Eligible to be PI only for studies that are multi-site clinical trials.
    4. Studies must be multi-center/multi-site.  Stanford must be one of at least two sites, and the “Stanford” site is defined as and includes the VA/PAIRE, LPCH, SHC, and their affiliated institutions.
    5. The Clinician Educator may not be the overall multi-center trial director.
    6. No minimum time in rank is required.
    7. The waiver request from the Department Chair must state that the CE will have protected time available to conduct the prospective research study and that the Department Chair confirms the competency of the CE to serve as PI.




C.2 Practice of Medicine Clinician Educator (Faculty) Waiver to serve as Principal Investigator:


    IMPORTANT:
    #1:
    Please download and read this document for detailed eligiblity criteria:

    CE PI Waiver Rationale, Criteria and Process Document
    download PDF file >>) (Revised 04/27/12) PDF

    #2. Please see the Comparison of CE PI Waiver Chart below >>

    #3: Please see the revised CE PI Waiver Practice of Medicine Checklist and the new CE PI Practice of Medicine PI Waiver Summary Form below >>


    Criteria:

    1. Must hold rank of Clinical Assistant Professor, Clinical Associate Professor, or Clinical Professor. 
    2. Clinical Instructors are not eligible.
    3. The study must directly benefit the CE's patients and improve CE's ability to practice optimal medicine.  For details on the types of research studies permitted, see CE PI Waiver Rationale, Criteria and Process Document above.
    4. The study must be exclusively or very highly focused on the patient populations served by CEs practicing at SHC, LPCH, PAVA, SCVMC, and affiliated medical centers.
    5. The waiver request must include a statement confirming the Department Chair approves that the CE will take appropriate time away from primary clinical care and educational responsibilities to conduct the prospective research study and that the PI will have access to resources necessary to accomplish the research


    C3. Comparison of Clinical Educator PI waivers

    Comparison of Clinical Educator PI Waivers
    Assistant, Associate or Professor (Instructors are not eligible)
      Multi-Site Waiver Practice of Medicine Waiver
    Protocol Provided by industry sponsor Written by PI or other
    Other sites Stanford at least 1 of 2 sites; Stanford=VA, LPCH, SHC, affiliated medical centers Highly focused on Stanford, VA, LPCH and affiliated medical centers
    Topic Industry sponsored clinical trial of drug, device, diagnostic Focused on the local practice of medicine and its improvement
    Patients/ subjects No guidelines or restrictions on subjects Exclusively highly focused on patients within Stanford, VA, LPCH, affiliated medical centers including PI's practice
    Funding Industry Any source
    F&A Rate 28% generally Varies by location and funding source
    Other Information CE cannot be over-all multi-site study PI Call your Research Process Manager (RPM) in RMG for further information more >>

     


D.   Expanded Pilot PI waiver option for:
    Clinical Fellows,
    Instructors with M.D. or M.D./Ph.D. Degrees,

    Postdoctoral Scholars with M.D. or M.D./Ph.D. Degrees



Background
On Dec. 2, 2010, the Faculty Senate approved a proposal that allows Clinical Fellows and M.D. Postdoctoral Scholars with two or more years of research training to request a PI waiver that allows him/her to serve as PI on an extramural independent RO1-type grant** on a one-time basis without the possibility of renewal (unless the trainee is appointed to the Stanford faculty). (Instructors with M.D. or M.D./Ph.D degrees have subsequently been added to the eligibility.) Stanford report article>>

**What is an R01-type grant?
It is an extramural independent research grant (federal or non-federal) that provides at least $125,000 in direct costs per year for at least two years.  The funding should not cover mostly the PI's salary.

This one-time opportunity is restricted to only one grant application and its allowable resubmissions, with no possibility of additional applications or resubmissions beyond those allowable for the specific grant application.  Only 10 waivers per year will be allowed during this 4-year evaluation period.   The Faculty Senate approval includes a 4-year evaluation process that will be monitored by the Committee on Research (C-Res) and the Dean of Research.   The Faculty Senate will then consider the possibility of an extension, termination, or permanent incorporation into Stanford policy (Research Policy Handbook, RPH 2.4) at the end of the evaluation period.  For more information, see >>

Consideration (eligibility) Criteria
Faculty mentors may request a PI waiver for Instructors with M.D. or M.D./Ph.D.s, Clinical Fellows and Postdoctoral Scholars with M.D. or an M.D. plus an advanced degree (i.e., M.D./Ph.D.) who meet the following criteria to serve as PI on an extramural independent RO1-type grant on a one-time basis without the possibility of renewal.

  • Only Instructors with an M.D. or M.D./Ph.D., Clinical Fellows and Postdoctoral Scholars who hold an M.D or an M.D. plus some other advanced degree (i.e., M.D./Ph.D.) are eligible. Clinical Instructors and Research Associates are not eligible.
  • Candidates must have two or more years of research training
  • In addition, applicants should have a research record (publications and prior research training) that is consistent with their having a reasonable chance of success in order to receive this specific PI career development waiver opportunity.
  • Written approval with signatures of the faculty advisor and department chair/ institute or center director are required to document that the individual will be assigned the appropriate space and other resources necessary to support the work described in the grant application for the duration of the grant period, should it be awarded.
  • Signature of the postdoctoral trainee is required to document that s/he understands the terms of the waiver, including that there is no possibility of renewal if awarded, and no possibility of subsequent submissions (beyond those allowable for the specific grant application) should the application be unsuccessful.
  • If the Postdoc is successful in receiving an award, the department must appoint him/her as an Instructor.
  • In addition, the School will not permit graduate students to be supported on any grant awarded under this PI career development waiver exception. It may be, however, that the grant will have funding to appoint a postdoctoral fellow. If so, the PI would be responsible for the day-to-day research supervision of the work of the postdoc. However, the overall career mentoring of the postdoc would be the responsibility of an Academic Council or Medical Center Line faculty member.

    (How do I prepare the Pilot PI waiver memo guidelines? see below>>)

Why are only postdoctoral fellows, clinical fellows and Instructors with M.D. or M.D./Ph.D degrees eligible? Why are individuals with Ph.D.s not eligible for this Pilot PI waiver program?

"To help the career development of physician-scientists-in-training – MDs who plan careers conducting research and treating patients – the Faculty Senate last week approved a trial plan to allow them to serve as the lead scientists on federal grants."

"He [Dr. Harry Greenberg] said physician-scientists who join the faculty of clinical departments in medical schools have two primary ways to earn money – clinical care and grants. Early in their careers, if they do not have independent grant support, they face tremendous economic pressure to shift more and more of their attention to patient care and away from research, due to financial constraints. 'This plan would permit people to have protected time from the beginning to get their research going and to protect them from having to do that clinical work right at the get-go,' Greenberg said." See Stanford report article>> *.

(*note: Instructors with M.D. and M.D./Ph.D. degrees, not mentioned in this original article, were subsequently made eligible for this Pilot PI waiver program.)

PI Waiver Request Memo Guidelines for Clinical Educator (Faculty)
IMPORTANT: Please read the CE PI waiver categories' eligibility criteria and descriptions above >> before proceeding.

Send your PI Waiver Memo directly to your Research Process Manager (RPM) or your Clinical Trial Research Process Manager (CT RPM) in the  Research Management Group (RMG).


Kathleen Thompson, the Director of RMG, and Debbie Leong-Childs, the Associate Director for Clinical Research Administration, will review and forward the memo to Dr. Harry Greenberg and Dr. David Stevenson
for their approval.

Please allow sufficient time for both of the Senior Associate Deans to review your waiver request (3-5 days).

checkbox  Use these guidelines only for the Clinician Educator (Faculty) PI Waiver Requests.

CE PI Waiver Checklist-multi-site clinical trials  checkbox
Send your PI waiver request directly to your department’s Clinical Trial RPM (CT RPM >>)


CE PI Waiver Checklist-practice of medicine (Rev. 05/01/12) checkbox
Send your PI waiver request directly to your department’s Research Process Manger (RPM >>)



checkbox
The PI Waiver memo* should include the following:


The PI Waiver memo should include the following in the order listed below:

CE Practice of Medicine PI Waiver Summary Form     new
Fillable PDF file >>   PDF file 
(Download and complete this fillable PDF form only if you are submitting a CE Practice of Medicine PI Waiver Request Memo)  

Other memo requirements:
1. Request for a PI Waiver on a specific proposal must be written on departmental letterhead and signed by your Division Chief and your Department Chair. )
2. Address the memo to Dr. Harry Greenberg, Senior Associate Dean of Research and David Stevenson, Vice Dean and Senior Associate Dean for Academic Affairs. (Reminder: although the memo is addressed to Drs. Greenberg and Stevenson--do not deliver it directly to him. It must be delivered instead to your RPM or CT RPM first.)
3. Add a signature lines to the document to allow Dr. Harry Greenberg and Dr. Stevenson to provide their approval.
4. Name of faculty member, degrees and appointment
5. Provide the sponsor name
6. Provide the proposal title
7. The request should address the exception criteria
8.a For the CE Multi-site Clinical Trial waiver
, the request from the division chief and/or department chair stating that the CE will have protected time available to conduct the prospective research study and that the division chief and department chair confirm the competency of the CE to serve as PI.
8 b. For the CE Practice of Medicine waiver, the request should include a statement confirming that the division chief and/or department chair has approved the faculty member having the appropriate time away from their primary clinical care and educational responsibilities as well as provide access to any necessary resources needed to accomplish the research.
9a. Attachment to the CE Multi-Site Clinical Trial PI Waiver Memo:

     CV
9b. Attachments to the CE Practice of Medicine PI Waiver Memo:
     Abstract
     Biosketch
     A photocopy of the sponsor's program announcement (if applicable)


 
(See the separate PI Waiver Memo Guidelines for Career Development Awards, Conferences/workshops, Early PI ship, Interdisciplinary projects.)

Copies of the approved waiver letters will be maintained in RMG.

 

PI Waiver Guidelines and Checklists for Career Development, Early PI ship, Conferences and Workshops, Interdisciplinary Projects and Rare Exception

Send your PI Waiver Memo directly to your Research Process Manager (RPM) in the  Research Management Group (RMG).

Kathleen Thompson, the Director of RMG, will review and forward the memo to Dr. Harry Greenberg for his approval. Use these guidelines only for the following PI Waiver types: 


checkbox PI Waiver Checklists

Career Development   Excel
Conference Workshop   Excel 
Early PI ship   Excel
PI waiver for project that is part of a large interdisciplinary program   Excel
Rare Exception   Excel


checkbox
The PI Waiver memo* should include the following:


1.  Request for a PI Waiver on a specific proposal must be written on departmental letterhead and signed by your Division Chief and your Department Chair. )

2.  Address the memo to Dr. Harry Greenberg, Senior Associate Dean of Research*. (Reminder: although the memo is addressed to Dr. Greenberg--do not deliver it directly to him. It must be delivered instead to your RPM first.)

3.  Add a signature line to the document to allow Dr. Harry Greenberg to provide his approval. 

4.  Name of PI, degrees and appointment

5.  The type of the waiver (Early PIship, Conference/workshop, Career Development Award, Part of a Large Interdisciplinary Project)

6.  For PI waivers under career development, the waiver should indicate that the project will be conducted in existing laboratory space assigned to the department; that incremental space will not be required; and approval of this PI waiver does not promise the candidate a faculty position.

7.  The specific request should address the exception criteria for each PI Waiver type

8. The name and type of proposal

9. The sponsor

Discussion of the appropriateness of the waiver, focusing on the points specified in the PI Eligibility policy statement

Attachments to the PI Waiver Memo for Career Development Awards: Senior Research Associates/Scientists; Post-Docs 

1.  A  biosketch

2.  A  photocopy of the eligibility requirements of the sponsor's RFP must be attached to the PI Waiver Memo to confirm that the funding opportunity is a career development award (note: this is not needed for government awards)
 
Copies of the approved waiver letters will be maintained in RMG.







Pilot PI Waiver Request Memo Guidelines for
           Clinical Fellows
           Postdoctoral Fellows (with M.D., M.D./Ph.D. degrees)
           Instructors (with M.D. or M.D./ Ph.D degrees)


Process:

  1. checkbox The Primary Mentor should contact Dr. Harry Greenberg, the Senior Associate Dean for Research, at harry.greenberg@stanford.edu to discuss the potential candidate after s/he has obtained support from the Department Chair.
  2. checkbox Determine the internal deadline (3-4 waivers will be approved with each deadline until the allowed 10 waivers have been granted):

    Internal Deadline

    Sponsor Deadline

    March 1

    June 1- September 30

    August 1

    October 1-January 31

    November 1

    February 1 - May 31



  3. checkboxThe Faculty Mentor and the Instructor, Clinical Fellow or Postdoctoral Fellow with M.D. or M.D. plus advanced degree (i.e., M.D./ Ph.D. degree) must complete the Postdoctoral Trainee Career Development Pilot PI Waiver Request Formpdf and attach the appropriate documentation which includes:

       √ Memo that addresses the consideration criteria (i.e., states the department’s commitment to his/her career, describes the Applicant’s unique qualifications and why s/he is likely to receive the grant. The memo should include information on the location of the proposed research space, locations of other resources required for the period of this grant including equipment, research staff, etc., and confirm that if awarded the R01-type grant, the department will appoint the individual in an Instructor position)
       √ 1-page description of research project
       √ Applicant's biosketch

  4. By the March 1, August 1 or November 7 internal deadline, please submit the completed pilot PI waiver request form and documentation (memo, research project description, applicant biosketch) in one PDF file via email attached to:
    Jeanne Heschele
    Research Management Group
    Phone: 650-245-2351
    Email: jheschele@stanford.edu
  5. Selection process:
    The proposals will be distributed to an internal School of Medicine review committee. Up to three candidates for each internal deadline* may receive approval for their PI waiver and the OK to proceed with their one-time R01-type application for their proposed research. (*A fourth candidate may receive approval for one of the internal deadlines to bring the annual total of approved Expanded PI waivers to 10.)
    After the internal review committee and Dr. Harry Greenberg, the Senior Associate Dean for Research, have completed their reviews, Jeanne Heschele will subsequently distribute copies of the Expanded PI Waiver Pilot request forms to each faculty mentor indicating whether or not the request was approved.
    Up to ten Expanded PI waivers may be approved each year during the 4 year evaluation period from 2011-2014 permitted by the Faculty Senate.

 





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