April 30, 2003

TO: Deans, Directors, and Department Heads

FROM: Richard C. Powell, Vice President for Research and Graduate Studies

SUBJECT: Status as a "Principal Investigator"

Recently it has been brought to my attention that there is confusion about who may serve
as a principal investigator on projects being conducted under the auspices of the
University of Arizona. The principal investigator is the individual bearing primary
responsibility for all essential aspects of the work being carried out, including technical
compliance, completion of programmatic work, fiscal stewardship of sponsored funds,
and compliance with administrative requirements of the project. With the oversight
responsibility implicit in the University's acceptance of outside funds for a project, the
University must be in a position of authority over the principal investigator's actions.
The general rule is that a principal investigator must be an employee of the University of
Arizona.

In the research context, employee means that, either:

1. The University has issued and the individual has signed an annual Notice
of Appointment or Notice of Reappointment, whether or not the
individual receives state funding or receives funding through the
University from outside sources such as grants, contracts or other non-
state sources of funding; or

2. The individual

a. has received a Notice of Association from the President of the University; and

b. has a contractual relationship with an entity affiliated by contract with the University (for example, University Physicians Inc., Veterans Administration, Scottsdale Healthcare or others); and

c. agrees to be bound by and subject to all policies and rules that apply to all UA employees related to their conduct of such projects; and

d. has signed an agreement with the University in which the responsibilities for claims arising out of research activities and professional services are clearly delineated, which agreements shall be reviewed by the University Attorneys' Office prior to their execution; and

e. has an appointment in a College in which such project(s) would be conducted most appropriately, which appointment does not violate any other policies, practices or agreements of that or any other
College.

Notices of Association and affiliations that do not require such individuals to sign an
agreement annually such as that set forth in paragraph 2.d. above with either the
University of Arizona or one of its contractually affiliated organizations do not confer
employee status.