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Frequently Asked Questions
Senior/Key Personnel
Initial Posting: September 3, 2010
Last Revised: May 16, 2011

  A. Definitions

  1. Senior/key personnel designated in the application by applicant organization:
  2. Senior/key personnel named in NoA designated by NIH:
  3. Other significant contributors (OSC):
  4. Consultant:
  5. Measurable Effort:
  6. Person months:
  7. Change in status, including absence, of PD/PI and other senior/key personnel named in the NoA (for senior/key personnel):

  B. All Applications

  1. Where in the SF 424 (R&R) application do I designate individuals as senior/key personnel?
  2. Where in the PHS 398 application do I designate individuals as senior/key personnel?
  3. Whom should be designated as senior/key personnel?
  4. What documentation/information is required for senior/key personnel?
  5. What documentation/information is required for other significant contributors?
  6. How does NIH determine which senior/key personnel are named on the award?
  7. Why aren't all individuals designated by the applicant organization as senior/key personnel named in the NoA?
  8. Our application includes post docs with measurable effort, who are neither senior/key nor OSC's. Should we include their biosketches?
  9. The PD/PI would like to designate in the application all personnel as senior/key. Should we do so?
  10. Does designating an individual as senior/key provide a benefit or advantage to the individual?
  11. Should everyone with measurable effort be designated as senior/key?
  12. Is there a minimum number of personnel that should be designated as senior/key?
  13. Is there a maximum number of personnel that can be designated as senior/key?
  14. How do I designate in the SF 424 (R&R) application more than 40 individuals as senior/key?
  15. Must senior/key personnel be US citizens?
  16. Is an eRA Commons ID required for all senior/key personnel?
  17. Where in the SF 424 (R&R) application do I designate other significant contributors and include their biosketches?

  C. Consultants

  1. Should a consultant be designated as senior/key personnel?
  2. Should a consultant designated senior/key personnel be included in Budget Section A of the SF 424 (R&R) budget component?
  3. Should a consultant have measurable effort?
  4. What documentation/information is required for consultants?

  D. All Non-Competing Progress Reports

  1. Must we include in the progress report biosketches for all new personnel?
  2. Must we include in the progress report biosketches for all senior/key personnel?
  3. Should we include in the progress report a list of all senior/key personnel?
  4. Must I include all senior/key personnel in the All Personnel Report?

  E. Non-SNAP Progress Reports

  1. Where do we indicate significant changes of level of effort for senior/key personnel?
  2. Must we submit other support for all senior/key personnel?

  F. SNAP Progress Reports

  1. Must we include all senior/key personnel in our response to SNAP question 1 (Has there been a change in the other support of senior/key personnel since the last reporting period?) ?
  2. Where do we address changes in level of effort for senior/key personnel not named on the NoA for SNAP awards? (i.e., senior/key personnel who are not addressed in SNAP question 2).

  G. Prior Approval Requirements

  1. Do changes in status of senior/key personnel require prior approval from NIH?
  2. How do we request prior approval from NIH for a change in status?
  3. Does change in level of effort for senior/key personnel require prior approval from NIH?
  4. Do we need prior approval from NIH to increase effort?
  5. Is prior approval from NIH required for a change in status during a no-cost extension?
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  A. Definitions

  1. Senior/key personnel designated in the application by applicant organization:
    The program director/principal investigator (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 request salaries or compensation.
  2. Senior/key personnel named in NoA designated by NIH:
    PD/PI(s) are always considered senior/key personnel and are always named in the Notice of Award (NoA). NIH program officials use discretion in identifying in the NoA senior/key personnel other than the PD/PI(s), and may identify individuals that are considered critical to the project, i.e., their absence from the project would have a significant impact on the approved scope of the project. The prior approval requirement for changes in status of personnel applies only to those senior/key personnel named in the NoA. Limiting the number of individuals that are named in the NoA does not diminish the scientific contribution to the project of the senior/key personnel not named in the NoA; it does reduce the number of individuals subject to the prior approval requirement.
  3. Other significant contributors (OSC):
    Individuals who commit to contribute to the scientific development or execution of the project, but do not commit any specified measurable effort (i.e., person months) to the project. These individuals are typically presented at effort of “zero person months” or "as needed." Individuals with measurable effort may not be listed as Other Significant Contributors (OSCs). Consultants should be included if they meet this definition.
  4. Consultant:
    An individual who provides professional advice or services for a fee, but typically not as an employee of the engaging party. In unusual situations, an individual may be both a consultant and an employee of the same party, receiving compensation for some services as a consultant and for other work as a salaried employee. To prevent apparent or actual conflicts of interest, grantees and consultants must establish written guidelines indicating the conditions of payment of consulting fees. Consultants may also include firms that provide paid professional advice or services.
  5. Measurable Effort:
    The effort of PD/PI(s), faculty and other senior/key personnel devoted to a project expressed in terms of “person months” greater than zero. If consultants are considered senior/key personnel, they must have measurable effort expressed in person months.
  6. Person months:
    The metric for expressing the effort (amount of time) that PD/PIs, faculty and other senior/key personnel devote to a specific project. The effort is based on the type of appointment of the individual with an organization, e.g., calendar year (CY), academic year (AY), and/or summer term (SM); and the organization’s definition of such. The effort is expressed as a percentage of the total institutional appointment. See, Frequently Asked Questions Regarding the Usage of Person Months.
  7. Change in status, including absence, of PD/PI and other senior/key personnel named in the NoA (for senior/key personnel):
    Change in status is defined as withdrawal from the project, absence from the project for any continuous period of three months or more, or reduction of time devoted to the project by 25 percent or more from the level that was approved at the time of initial competing year award. For example, a proposed change from 2 calendar months effort to 1.5 calendar or fewer months effort would require prior approval. Prior approval is only required for a change in status for the PD/PI or other senior/key personnel specifically named in the NoA.
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  B. All Applications

  1. Where in the SF 424 (R&R) application do I designate individuals as senior/key personnel?
    Designate them on the Senior/Key Person Profile (Expanded) Component of the SF 424 (R&R).
  2. Where in the PHS 398 application do I designate individuals as senior/key personnel?
    Designate them under “SCIENTIFIC/KEY PERSONNEL” on “Form Page 2 (continued)” of the PHS 398.
  3. Whom should be designated as senior/key personnel?
    The PD/PI(s) are always considered senior/key personnel. The PD/PI(s) should designate other personnel as senior/key only if they fit the definition (see above) or as instructed in the FOA.
  4. What documentation/information is required for senior/key personnel?
    Biosketches and levels of effort greater than zero person months are required of all personnel designated in the application as senior/key. For most applications, you will receive an error message when completing the SF 424 (R&R) detailed budget component if you list individuals in Section A and do not provide level of effort greater than 0.00. If the applicant is notified that an application is being considered for funding by NIH, the applicant organization will need to submit other support information for all personnel identified as senior/key in the application as part of the Just-in-Time process.
  5. What documentation/information is required for other significant contributors?
    Biosketches are required for all personnel identified in the application as other significant contributors. However, other support information is not required.
  6. How does NIH determine which senior/key personnel are named on the award?
    All PD/PI(s) are named in the NoA. NIH program officials use discretion in identifying in the NoA senior/key personnel other than the PD/PI(s). Generally, these are individuals whom the IC considers critical to the project, i.e., their absence from the project would be expected to impact the approved scope of the project. Change in status of senior/key personnel named in the NoA requires prior written approval from the NIH.
  7. Why aren't all individuals designated by the applicant organization as senior/key personnel named in the NoA?
    All PD/PI(s) are named in the NoA. NIH program officials use discretion in identifying in the NoA senior/key personnel other than the PD/PI(s). This does not diminish the scientific contribution to the project of the other senior/key personnel; it merely limits the number of individuals that are affected by the prior approval requirement to those specifically named in the NoA. See Section G. for prior approval requirements.
  8. Our application includes post docs with measurable effort, who are neither senior/key nor OSC's. Should we include their biosketches?
    Do not include them. Biosketches are only required for senior/key personnel and OSC’s.
  9. The PD/PI would like to designate in the application all personnel as senior/key. Should we do so?
    No. Keep in mind the term “senior/key” applies only to individuals who contribute to the scientific development or execution of a project both substantively and measurably. If you misidentify personnel as senior/key, you will unnecessarily increase your burden for the preparation of the application, submission of Just-in-Time information, and annual reporting requirements.
  10. Does designating an individual as senior/key provide a benefit or advantage to the individual?
    NIH is unaware of any benefit or advantage to a “senior/key” designation. NIH expects the applicant organization’s designation of senior/key personnel be limited to individuals who contribute to the scientific development or execution of a project both substantively and measurably. Any perceived benefit or advantage an individual may receive from his or her institution or from another entity as a result of a senior/key designation would be unintended and not within NIH’s purview.
  11. Should everyone with measurable effort be designated as senior/key?
    No. Only those who contribute to the scientific development or execution of a project both substantively and measurably should be designated as senior/key, as well as any personnel specifically instructed for designation in the FOA.
  12. Is there a minimum number of personnel that should be designated as senior/key?
    Yes, the PD/PI(s) is/are always designated as senior/key. If additional individuals on the project meet the definition (see above), they should also be designated as senior/key.
  13. Is there a maximum number of personnel that can be designated as senior/key?
    No. You should designate individuals as senior/key based upon their roles and contributions to the project.
  14. How do I designate in the SF 424 (R&R) application more than 40 individuals as senior/key?
    Once you have entered data for the first 40 senior/key individuals, the Additional Senior/Key Person Form Attachments section will become available.
  15. Must senior/key personnel be US citizens?
    Not for research programs. However, NIH Training and Career Development programs do have a citizenship requirement for trainees, fellows, participants, and Career Development candidates. FOAs should be reviewed to determine if there are any additional citizenship requirements necessary in a specific application.
  16. Is an eRA Commons ID required for all senior/key personnel?
    An eRA Commons ID is required for all PD/PIs at the time of application. Additionally, an eRA Commons ID is required for anyone in a postdoctoral role and the eRA Commons ID must be reported in the All Personnel Report in the non-competing progress even if the post doc is not senior/key.
  17. Where in the SF 424 (R&R) application do I designate other significant contributors and include their biosketches?
    Other significant contributors should be listed on the Senior/Key Person Profile after all Senior/Key Persons, and their biosketch uploaded using the “Attach Biographical Sketch” upload feature.  Other support is not required or accepted for other significant contributors since considerations of overlap do not apply to these individuals.
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  C. Consultants

  1. Should a consultant be designated as senior/key personnel?
    Generally, a consultant is not considered senior/key personnel. However, if the consultant contributes to the scientific development or execution of a project substantively and measurably, he/she should be designated as senior/key personnel and would be included in the Senior/Key Person Profile Component.
  2. Should a consultant designated senior/key personnel be included in Budget Section A of the SF 424 (R&R) budget component?
    Only if the consultant designated as senior/key is an employee of the applicant organization. Otherwise, consultant costs should be included in section F.3 Consultant Services.
  3. Should a consultant have measurable effort?
    If the consultant is designated as senior/key personnel, the consultant must have measurable effort.
  4. What documentation/information is required for consultants?
    Grantees should describe in the budget justification the services to be performed by the consultant(s) and include the number of days of anticipated consultation, the expected rate of compensation, travel, per diem, and other related costs for each. If the consultant is also designated senior/key personnel, see question B.4.
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  D. All Non-Competing Progress Reports

  1. Must we include in the progress report biosketches for all new personnel?
    Only if the individuals are designated senior/key personnel AND you have not previously submitted biosketches for those individuals.
  2. Must we include in the progress report biosketches for all senior/key personnel?
    Only for individuals for whom you have not previously submitted biosketches.
  3. Should we include in the progress report a list of all senior/key personnel?
    No. NIH transitioned from the Key Personnel Report to the All Personnel Report October 1, 2009.  Follow the PHS 2590 instructions for the completion of the All Personnel Report.  For additional questions about the All Personnel Report, see All Personnel Report Frequently Asked Questions.
  4. Must I include all senior/key personnel in the All Personnel Report?
    Always report the PD/PI(s) regardless of the level of effort.  For all other personnel, only those who participate for one person month or more should be included in the All Personnel Report regardless of senior/key designation.  For additional questions about the All Personnel Report, see All Personnel Report Frequently Asked Questions.
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  E. Non-SNAP Progress Reports

  1. Where do we indicate significant changes of level of effort for senior/key personnel?
    In the budget justification.  Effort for all personnel is listed in the detailed budgets; however, you should note in the budget justification significant changes in level of effort for senior/key personnel from what was approved in the competing year award.  Please note that for calculating significant changes, effort changes are cumulative.  This does not apply to OSC's because they are not listed anywhere on the budget.

    Example for calculating significant reduction:
    PD/PI effort in -01 year award = 6 CM
    PD/PI effort in -02 year progress report = 5 CM (~16% reduction, not significant)
    PD/PI effort in -03 year progress report = 4 CM (~33% reduction from -01 year*, significant reduction which must be reported in budget justification)

    *While the reduction in effort from the -02 year to the -03 year in this example is only 20%, the reduction is calculated from the effort in initial competing year award.
  2. Must we submit other support for all senior/key personnel?
    Yes, submit the active other support for all senior/key personnel, regardless whether they are named in the NoA. This does not apply to OSC's. Nor does it apply to everyone listed in the All Personnel Report.
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  F. SNAP Progress Reports

  1. Must we include all senior/key personnel in our response to SNAP question 1 (Has there been a change in the other support of senior/key personnel since the last reporting period?) ?
    Yes, you must address the changes in other support for any individual you designated as senior/key personnel regardless whether they are named in the NoA.  You must also include other support for any new personnel you designate as senior/key personnel.  This question does not apply to OSC's.  Nor does it apply to everyone listed in the All Personnel Report.
  2. Must we include all senior/key personnel in response to SNAP question 2 (Will there be, in the next budget period, a significant change in the level of effort for the PD/PI(s) or other senior/key personnel designated on the NoA from what was approved for this project?)?
    No, the question is only applicable to those individuals named in the NoA.
  3. Where do we address changes in level of effort for senior/key personnel not named on the NoA for SNAP awards? (i.e., senior/key personnel who are not addressed in SNAP question 2).
    In the SNAP progress report, you are not required to address changes in level of effort for senior/key personnel not named in the NoA. If you choose to address this, the appropriate place to do so is in the Progress Report Summary section.
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  G. Prior Approval Requirements

  1. Do changes in status of senior/key personnel require prior approval from NIH?
    Yes, but only if the senior/key personnel are named on the NoA. If the individual is not named on the NoA, you do not need prior approval from NIH to make changes in status.
  2. How do we request prior approval from NIH for a change in status?
    Send a request, signed by the AOR, to the GMO. Only the GMO can approve the change in status. The program official is not authorized to approve change in status requests.
  3. Does change in level of effort for senior/key personnel require prior approval from NIH?
    Only if the individual is named in the NoA and the change would reduce time devoted to the project by 25 percent or more from the level that was approved at the time of the initial competing year award.
  4. Do we need prior approval from NIH to increase effort?
    As long as the increase would not result in a change of scope, you do not need prior approval from NIH to increase effort.
  5. Is prior approval from NIH required for a change in status during a no-cost extension?
    Yes. Prior approval from NIH is required for a change in status during a no-cost extension.

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