I. Policy Summary

Classroom and education activities at NJIT may involve assignments that include the use of research methods (such as questionnaires, interviews, or surveys) that involve interaction with living individuals. It is the responsibility of the class instructor or faculty advisor to determine whether the assignment or activity requires the approval of the Institutional Review Board (IRB) which governs human subjects research at the university.

II. Policy Purpose

This guidance is intended to help instructors make the determination whether an assignment or activity requires IRB approval. If there is any doubt or an instructor would like confirmation of their determination, they can contact the IRB co-chairs at irb@njit.edu.

III. Policy Scope and Applicability

This policy is in effect for all units of NJIT.

IV. Definitions

Research: Research is defined as "a systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to generalizable knowledge." (45 CFR 46.102[1])

V. Policy Statement

All human subject research must be approved by NJIT's IRB. Certain educational activities resemble human subject research, but do not meet the regulatory definition of research as defined in 45 CFR 46.102(1). This guidance is aimed to help instructors determine if their educational activities meet this definition or not.

In determining whether IRB approval is necessary, this is the key question for instructors and advisors. Is the classroom activity or assignment designed to develop or contribute to generalizable knowledge?

1. If the activity is not designed to contribute to generalizable knowledge, but rather to provide instruction or pedagogy concerning research methods, the activity is not considered research for regulatory purposes. There may be a research question driving the collection of data, but there is no intent for the collected data to lead to new knowledge (e.g. there may be too few individuals involved to reach any generalizable conclusion).

So, a class assignment that is intended to give students experience with and teach them how to conduct a survey, distribute a questionnaire, or interview individuals, would not constitute research. Likewise, classroom presentations of the results of such surveys, questionnaires or interviews, where the intent is to teach how to present research results, would also not qualify as research. 

While these activities are not research, it is expected that they will be carried out ethically. Instructions using such activities are expected to explain the potential risks involved with human subjects' research to the students, and they should take care to eliminate potential harm from these educational activities. For example, unless a necessary part of the pedagogy, care should be taken to avoid questioning that might prove harmful to subjects (such as data about the use of drugs, physical or sexual abuse, sexual activity, or illegal activity).

Individuals that are asked to take part in these activities should be told that the projects are part of an educational activity to fulfill. A course requirement and that all identifiable data collected will not be made public. It is the instructor's responsibility to make sure that the data collection is done in a way such that the individuals providing the data cannot be directly or indirectly identified.

VI. Procedures

After the instructor makes a determination according to the guidelines in Section V., one of the following should occur:

• If it is determined that the activity does not meet the definition of research discussed above, then no further interaction with the IRB is necessary for this activity to commence.

OR

• If the activity is designed to contribute to generalizable knowledge, then it is research as defined by 45 CFR 46.102(l) and requires IRB approval. The instructor or advisor must assume overall responsibility for such projects and ensure compliance with the approved IRB protocol.

OR

• If the activity is not designed to contribute to generalizable knowledge, but the instructor or student determines after starting or completing the activity that it has provided evidence for pursuing a research project, the resulting study would require IRB approval. This might happen, for example, if in doing a class assignment a correlation between two kinds of data is observed and the student or instructor decides it is worth pursuing a research study of that correlation.

VII. Roles and Responsibilities

It is the responsibility of the class instructor or faculty advisor to determine whether the assignment or activity requires the approval of the IRB. In turn, the IRB will provide guidance and approval for any protocols submitted to it regarding human subjects' research at the university.

VIII. Authority and Responsibility

The Institutional Review Board holds institutional authority for the issues covered in this policy. Any questions regarding this policy should be directed either to the IRB co-chair(s) at irb@njit.edu or the director for research compliance and services in the Office of Research.

Related Policies and Regulations

2. Human Subjects Research
   1. Exempt Research Performed in International Settings
      1. Principal Investigators for IRB Protocols

I. Policy Summary

Full-time NJIT faculty and staff are authorized to submit protocols for consideration by the NJIT IRB. Other members of the NJIT community may be co-investigators on IRB protocols as explained in the policy.

II. Policy Purpose

The purpose of this policy is to delineate which members of the NJIT community may act as principal investigators on protocols submitted to the IRB.

III. Policy Scope and Applicability

This policy is in effect for all units of NJIT and applies to all protocols submitted to the IRB.

IV. Definitions

Institutional Review Board (IRB): an administrative university committee charged with the evaluation of human subject research in accordance with federal regulations and institutional policies. The committee reports to the senior vice provost for research, but acts autonomously. IRB committee members and chairs serve on the basis of three-year renewable appointments.

IRB administrator: a staff member tasked with assisting the chair(s) of the IRB with management of all administrative processes related to maintaining IRB workflow and processes. This person is tasked with assisting and training the NJIT community on IRB processes. The current IRB administrator is the director of research compliance and services.

V. Policy Statement

All full-time faculty and staff may submit protocols for consideration by NJIT's institutional review board. Students may be co-investigators on IRB protocols submitted to NJIT's institutional review board, but cannot independently submit protocols. A faculty member acting as an advisor must be the PI on all student-led protocols (See Appendix 1).

People holding part-time or visiting appointments at NJIT may be co-investigators on protocols submitted to NJIT's institutional review board so long as a fulltime NJIT employee is a PI on the protocol.   

In rare cases, part-time employees may act as principal investigators on protocols submitted to NJIT's institutional review board with prior approval from the senior vice provost for research and the IRB chair(s). The decision made by the senior vice provost for research and IRB chair(s) is final.

VI. Procedures

All IRB protocols are submitted via the NJIT online grant management system, Streamlyne. Eligible individuals have login access to the system to input their protocol details. Problems with access or questions on system functionality should be addressed to the IRB administrator.

VII. Roles & Responsibilities

The IRB is an autonomous university committee with the authority to approve or disapprove protocols involving human subject research as defined by 45 CFR 46.

The IRB administrator is responsible for assisting PIs and co-investigators with the process of protocol submission and assists the committee chair(s) in organizing all IRB related workflow and processes.

PIs and their co-investigators are responsible for submitting and completing protocols via Streamlyne for consideration by the IRB.

VIII. Authority and Responsibility

The senior vice provost for research holds institutional authority for the issues covered in this policy. Any questions regarding this policy should be directed either to the co-chairs of the NJIT IRB or the director of research compliance and services in the Office of Research.

Related Policies and Regulations
4.2 Human Subjects Research

VI. Procedures

All IRB protocols are submitted via our online grant management system, Streamlyne. Eligible individuals have login access to the system to input their protocol details. Problems with access or questions on system functionality should be addressed to the IRB administrator.

Adequate documentation demonstrating due diligence will be determined by the IRB co-chairs on a case by case basis. The director for research compliance and services is responsible for maintaining records of all such documentation.

VII. Roles & Responsibilities

The IRB is an autonomous university committee with the authority to approve or disapprove protocols involving human subject research as defined by 45 CFR 46.

The IRB administrator is responsible for assisting PIs and co-investigators with the process of protocol submission and assists the committee chair(s) in organizing all IRB-related workflow and processes.

PIs and their co-investigators are responsible for submitting and completing protocols via Streamlyne for consideration by the IRB.

VIII. Authority and Responsibility

The senior vice provost for research holds institutional authority for the issues covered in this policy. Questions related to this policy are to be directed to the co-chairs of the NJIT IRB.

The Office of Research holds institutional authority for the issues covered in this policy. Any questions regarding this policy should be directed either to the co-chairs of the NJIT IRB or the director of research compliance and services in the Office of Research.

Related Policies and Regulations
4.2 Human Subjects Research

I. Policy Summary

The university is committed to conducting research in a manner that promotes the integrity of research and maintains the public trust in activities performed by faculty and staff. It is the intent of the university to demonstrate that the research and the results of the research conducted at the university are not biased or prejudiced by any external commitments or significant financial interests of any person(s) with involvement in the design, conduct, reporting, or administration of the research project.

II. Policy Purpose

The purpose of this policy is to ensure that faculty and staff are aware of their responsibilities concerning financial conflicts of interest when performing research at the university.

III. Policy Scope and Applicability

This policy is in effect for all units of NJIT and applies to all sponsored programs.

IV. Definitions

Management plan - An action plan to address, to the extent possible, a financial conflict of interest, which can include reducing or eliminating the financial conflict of interest, so that the design, conduct, and reporting of research will be free from bias.

Financial Interest - Anything of monetary value, whether or not the value is readily ascertainable.

Financial Conflict of Interest (FCOI) - A significant financial interest that could directly and significantly affect the design, conduct, or reporting of research awards.

Significant Financial Interest - A significant financial interest is a financial interest of a senior key personnel, his/her spouse, and his/her dependent children which jointly equals or exceeds $5,000 and reasonably appears to be related to the senior key personnel's responsibilities. With regard to any publicly or non-publicly traded entity, the financial interest includes any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure. A financial interest exists with regard to intellectual property rights and interests, such as patents and copyrights, upon receipt of income related to such rights and interests. Remuneration includes salary and any payment for services not otherwise identified as salary, such as consulting fees, honoraria, and paid authorship. Equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value.

The term significant financial interest does not include the following types of financial interests:

• salary, royalties, or other remuneration paid by the University to senior key personnel if he/she is currently employed or otherwise appointed by the University, including intellectual property rights assigned to the University and agreements to share in royalties related to such rights.
• income from investment vehicles, such as mutual funds and retirement accounts, as long as senior key personnel do not directly control the investment decisions made in those vehicles.
• income from seminars, lectures, or teaching engagements and from service on advisory committees or review panels sponsored by a Federal, State, or local government agency, an institution of higher education,   an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

V. Policy Statement

The University requires individuals participating in sponsored projects to disclose any significant financial interests that may present actual or potential conflicts of interest with regards to externally sponsored projects and human subjects research. A conflict of interest exists when an employee's duty to the University can be prejudiced by actual or potential benefit from another source. Employees are required to conduct themselves at all times in accordance with good professional judgment for the benefit of the University and in such a manner as to not create a conflict of interest or appearance of such conflict.

When it is determined that a financial conflict of interest exists, the university will determine a management plan to mitigate the conflict. In rare cases, if a conflict cannot be managed, the university may require the personnel to recuse themselves from the project or remove the entity with which a conflict exists from participation in the project.

NJIT requires the completion of conflicts of interest disclosures before the funding for an award is disbursed and before submission of a protocol for human subjects’ research.

VI. Procedures

The director for research compliance coordinates and manages all procedures related to the administration of research-related FCOI reporting for both sponsored projects and IRB protocols. Escalation of any problems or concerns with regard to FCOI wil  be to the executive director, sponsored research programs administration and the senior vice provost for research.

All senior key personnel on sponsored projects or IRB protocols are required to complete the Streamlyne COI disclosure in order to disclose his/her significant financial interests and those of his/her spouse and his/her dependent children. This disclosure must be completed before or at the time the award is granted, annually by October 15, for the previous calendar year during the period of the award and within thirty days after a new financial interest arises during the period of the award.

Senior key personnel must disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on his/her behalf), related to their University responsibilities in relation to the research award. This and all other disclosures must be made in the Streamlyne system.

VII. Roles & Responsibilities

CITI training, Streamlyne records, and system administration are managed by the director for research compliance and services in the Office of Research.

The director for research compliance services is charged with maintaining accurate records of conflicts of interest. The director will review the FCOI disclosures in consultation with the director of pre-award services prior to the expenditure of funds to determine if a financial conflict of interest exists that could directly and significantly affect the design, conduct, or reporting of the research award.

If a financial conflict of interest exists, the director of research compliance services will report this finding to the assistant vice provost, sponsored research administration. The executive director will call for a meeting with the senior vice provost for research, the dean of the relevant college or school, and other appropriate university officers to determine if the conflict is manageable and, if so, will assist in developing and implementing a management plan. The assistant director of compliance will periodically review compliance with the management plan.

If new senior key personnel are identified, they will complete a FCOI disclosure and have it reviewed by the director of research compliance services prior to participation with an existing award.

VIII. Authority and Responsibility

The Office of Research holds institutional authority for the issues covered in this policy. Any questions regarding this policy should be directed either to the assistant vice provost, sponsored research administration or the director of research compliance services in the Office of Research.

Related Policies and Regulations

42 CFR 50, Subpart F

I. Policy Summary

Research involving human subjects at NJIT requires oversight by the NJIT Institutional Review Board (IRB). Federal guideines govern NJIT IRB protocols, membership and required training.

II. Policy Purpose

This policy describes the ways NJIT guarantees that research involving human subjects is upheld to high ethical standards and that research projects preserve the autonomy of people who volunteer to be subjects.

III. Policy Scope and Applicability

This policy is in effect for all units of NJIT and applies to all research involving human subjects and to all protocols submitted to the NJIT IRB.

IV. Definitions

The Common Rule (45 CFR 46, as revised in 2018) of the United States Department of Health and Human Services defines research as "a systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to generalizable knowledge." (§.102[l])

It also defines human subject as "a living individual about whom an investigator (whether professional or student) conducting research: 

i) Obtains information or biospecimens through intervention or interaction with the individual, and uses, studies, or analyzes the information or biospecimens; or 

ii) Obtains, uses, studies, analyzes, or generates identifiable private information or identifiable biospecimens." (§.102[e][1])

V. Policy Statement

Under a Federal-wide assurance with the United States Department of Health and Human Services, all research involving human subjects performed by NJIT faculty, staff, and students either on-campus or off-campus, including at other institutions, must be reviewed and approved prior to initiation by the NJIT Institutional Review Board (IRB).

The NJIT IRB follows all regulations as outlined in 45 CFR 46.

VI. Procedures

All current administrative procedures relating to human subjects research can be found on the NJIT Research Compliance website.

All IRB protocols are submitted via the NJIT online grant management system, Streamlyne. Eligible individuals have login access to the system to input their protocol details. Problems with access or questions on system functionality should be addressed to the IRB administrator.

Once the Institutional Review Board (IRB) has reviewed a protocol and approved for the procedures and subjects described in the protocol:

All research must be conducted in accordance with the procedures outlined in the approved protocol.

The protocol is approved until the expiration date listed in the approval letter and must be reviewed for renewal on an annual basis for as long as the research remains active. The PI must submit a request for Continuing Review at least 30 days prior to the expiration date. If the study’s approval expires, investigators must stop all research activities immediately (including data analysis) and contact the IRB Office for guidance.

The principal investigator is responsible for the following:

• Conducting the research in a manner consistent with the requirements of the IRB and federal regulations 45 CFR 46.
• Obtaining informed consent and research privacy authorizations using the currently approved forms and retain all original, signed forms, if applicable.
• Requesting approval from the IRB prior to implementing any modifications.
• Promptly reporting to the IRB any unanticipated problems involving risks to subjects, as well as serious and unexpected adverse events.
• Maintaining accurate and complete study records.
• Reporting all non-compliance issues or complaints regarding the project promptly to the IRB.

All research records must be kept for a minimum of three (3) years after the project is finished. Once the project is complete, the PI must submit a Request to Close to the IRB.

VII. Roles & Responsibilities

The IRB is an autonomous university committee with the authority to approve or disapprove protocols involving human subject research as defined by HHS Revised Common Rule 45 CFR 46.

The IRB administrator is responsible for assisting PIs and co-investigators with the process of protocol submission and assists the committee chair(s) in organizing all IRB-related workflow and processes.

PIs and their co-investigators are responsible for submitting and completing protocols via Streamlyne for consideration by the IRB.

VIII. Authority and Responsibility

The Office of Research holds institutional authority for the issues covered in this policy. Any questions regarding this policy should be directed to the senior vice provost for research at irb@njit.edu.

Related Policies and Regulations

Office for Human Research Protections (OHRP) 45 CFR 46.

OBJECTIVES 

The copyright policy of New Jersey Institute of Technology (NJIT) seeks to protect and promote the traditional academic freedom of NJIT’s faculty, staff, and students in matters of publication; seeks to balance fairly and reasonably the equitable rights of authors, sponsors, and NJIT; and attempts to ensure that any copyrightable material in which NJIT has an equity interest is utilized in a manner consistent with the public interest.

OWNERSHIP AND DISPOSITION OF COPYRIGHTABLE MATERIAL 

Copyright ownership and the rights thereof are terms defined by Federal law. NJIT believes that its copyright policy objectives will best be attained within the context of the Federal Law by defining the equities of ownership of copyrightable material in terms of the following categories:

A. Copyright ownership of all material (including unpatentable software, but excluding theses and books) which is developed in the course of or pursuant to a sponsored research or other agreement shall be determined in accordance with the terms of the sponsored research or other agreement, or in the absence of such terms, the copyright shall become the property of NJIT.

Comment: Normally, research contracts sponsored by the government provide the government with specified rights in copyrightable material developed in the performance of the research. These rights may consist of title to such data vesting solely in the government or the reservation of a royalty-free license to government, with title vesting in NJIT. In some cases, the government prohibits any private copyright ownership. Grants and other types of sponsored research agreements, whether by the government or by private industry, may, on the other hand, provide no specific provision concerning rights in such material. 

The purpose of this provision (which applies to all academic and research employees of NJIT) is to ensure that NJIT will be free to dispose of all such data in a manner consistent with its obligations to the sponsor and to the public.

In cases where a researcher wishes to publish Category A material in journals or other media, Federal law now requires the written consent of the owner of the copyright. Requests for such consent, which will normally be routinely provided, should be addressed to the Research Office. The Research Office is responsible for the processing and management of copyrights under the direction of NJIT’s Intellectual Property Committee.

B. Copyright ownership of all material (including unpatentable software but excluding theses and books) which is developed with the significant use of funds, space or facilities administered by NJIT, including but not limited to classes and laboratory facilities, but without any NJIT obligation to others in connection with such support shall reside in NJIT.

Comment: NJIT shall exercise its rights in such material in a manner that will best further NJIT’s basic aims as an educational institution, giving full consideration to making the material available to the public on a reasonable and effective basis, avoiding unnecessary exclusions and restrictions, and providing adequate recognition of the authors.

In this respect NJIT recognizes and reaffirms the traditional academic freedom of its faculty and staff to publish freely without restriction. In keeping with this philosophy, NJIT will neither construe the provision of office or library facilities as constituting significant use of NJIT space or facilities, nor will it construe the payment of salary from instructional accounts as constituting significant use of NJIT funds, except for those situations where the funds were paid specifically to support the development of such material.

Publications not prepared within the scope of an NJIT employee’s duties are excluded from the ownership provisions of this category. Textbooks developed through the use of classes are excluded from the provisions of this category, unless such textbooks were developed using NJIT-administered funds paid specifically to support such textbook development.

Unless significant use of university resources is utilized in the creation of instructional material, or the ownership is subject to research or contractual restrictions, the faculty member owns the copyright to the materials created. Subject to the terms of this policy, the faculty member shall also be deemed to own the course materials and/or curriculum outlines that they develop, whether in physical or electronic formats.

All persons who have developed copyrightable material through the significant use of NJIT space, funds, or facilities shall be required to transfer copyright ownership of such material to NJIT as a condition of such use.

C. Copyrightable material not within the provisions of Categories A and B of this policy shall be the sole property of the author, except for theses, as discussed below.

NJIT claims rights in inventions or discoveries, including computer software, which are or may be patentable. Such inventions or discoveries shall be covered by NJIT’s Patent Policy.

For certain copyrightable works, NJIT’s Patent Policy may apply and may be in conflict with this Copyright Policy. In such circumstances, the Patent Policy will take precedence over this Copyright Policy.

Theses created by students shall be governed by the following provisions:

D. Copyright ownership of theses generated by research which is performed in whole or in part by the student with financial support in the form of wages, salaries, stipend or grant from funds administered by NJIT shall be determined in accordance with the terms of the support agreement, or in the absence of such terms, shall become the property of NJIT.

E. Copyright ownership of theses generated by research performed in whole or in part utilizing equipment or facilities provided to NJIT under conditions that impose copyright restriction shall be determined in accordance with such restrictions.

F. Copyright in theses not within the provisions of Categories D and E of this policy shall be the property of the author. However, the student must, as a condition of a degree award, grant royalty-free permission to NJIT to reproduce and publicly distribute copies of the thesis.

As with faculty and research staff, NJIT wishes to encourage broad dissemination of all such material. Requests for permission to publish Category D and E theses should be addressed to the Office of Research.

COPYRIGHT ROYALTIES 

Royalty income received by NJIT through the sale, licensing, leasing, or use of copyrightable material, under Categories A and B, in which NJIT has acquired a property interest, will normally be shared with the author and the unit (department, laboratory, center, etc.) within NJIT were the material originated. The gross royalties received by NJIT will usually be distributed as follows:

1. To NJIT, 60%.

2. To the author(s), a total of:

• 35% of the first $50,000 in accumulated gross royalties,
• 25% of the next $50,000 in accumulated gross royalties,
• 15% of the accumulated gross royalties thereafter.

3. To the originating department, laboratory, or center within NJIT: 
 

• 5% of the first $50,000 in accumulated gross royalties,
• 15% of the next $50,000 in accumulated gross royalties thereafter.
• 25% of the accumulated gross royalties thereafter
  
   

Authorship shall be determined by the director of the originating unit (department, laboratory, center, etc.). If there is an appeal regarding the determination of authorship, that determination will be reviewed by the Senior Vice Provost for Research, equivalent, or their designee in consultation with the Office of the General Counsel. Where, after review, authorship cannot be determined, the percent share of royalties intended for the author shall be distributed instead to the originating unit (department, laboratory, center, etc.). (As used herein, the phrase “originating unit,” means the department, laboratory, center, etc., which administered the funds, space and facilities used in developing the copyrightable material.)

NJIT reserves the right at its discretion to deduct from gross royalty income prior to any such distribution, expenses such as litigation which may be incurred in enforcing or defending the copyright or in licensing the copyrightable material.

INVENTION AND COPYRIGHT AGREEMENTS

The policies set forth above constitute an understanding which is binding on NJIT faculty and staff, students, and others as a condition of their participating in NJIT research programs or their use of funds, space or facilities. Where NJIT may have had an obligation to assign rights in inventions or copyrights to a sponsor, or may itself acquire rights under this policy, it will require a formal invention and copyright agreement.

I. Policy Statement

New Jersey Institute of Technology (NJIT) is committed to complying with federal regulations regarding the proposing, expending, and documenting of cost sharing. It is the policy of the University to minimize, if not eliminate, all voluntary committed cost sharing.

NJIT will only provide cost sharing when it is:

1. Mandatory: Required by the sponsor as a condition of the award.
2. Statutorily Required: Necessary to meet specific program legislation.
3. Strategic: Deemed essential by the Senior Vice Provost for Research (SVPR) to the success of a highly competitive institutional proposal.

II. Purpose

The purpose of this policy is to ensure compliance with 2 CFR 200 (Uniform Guidance). Improperly documented cost sharing creates significant audit risk and unintentionally increases the University's organized research base, which can negatively impact the University’s F&A (indirect cost) rate.

III. Definitions

• Cost Sharing (Match): That portion of project costs not paid by the sponsor.
• Mandatory Cost Sharing: Required by the written terms of the RFP/RFA. Must be documented and reported.
• Voluntary Committed Cost Sharing: Resources pledged in the proposal (narrative or budget) that were not required by the sponsor. Once awarded, these become legally binding and auditable.
• Voluntary Uncommitted Cost Sharing: Effort or resources which is committed and budgeted for in a sponsored agreement. This is not auditable or reported.
• In-Kind: Non-cash contributions (e.g., volunteer time, donated equipment) provided by third parties.
• Cash Match: Direct funding from NJIT or non-federal third parties for project expenses (e.g., salary/benefits, equipment).

IV. Federal Regulatory Requirements (2 CFR 200.306)

Under Federal research proposals, voluntary committed cost sharing is not expected and cannot be used as a factor during the merit review of applications unless specifically allowed by the agency (e.g., NSF, NIH). To be acceptable, cost sharing must be:

1. Verifiable from the University’s official financial records.
2. Not included as cost sharing for any other federal award.
3. Necessary and Allocable to the project’s objectives.
4. Allowable under Subpart E—Cost Principles.
5. Non-Federal: Not paid by the federal government under another award (unless authorized by statute).

V. Categories of Cost Sharing

1. Personnel Effort (Cash Match)

The most common form of cost sharing is the allocation of NJIT-funded salary and fringe benefits for the PI or senior personnel. This is considered a "cash" transaction because it is documented in the payroll system.

2. Unrecovered Indirect Costs (F&A)

Unrecovered F&A is the difference between NJIT’s federally negotiated rate and the amount allowed by the sponsor. Including unrecovered F&A as cost sharing requires prior approval from the federal awarding agency.

3. Third-Party & In-Kind

Contributions from non-NJIT entities must be documented by a signed letter from the third party at the proposal stage and certified by the third party upon completion of the work.

4. Equipment

University-furnished space or existing equipment cannot be claimed as cost sharing because these costs are already captured in the University’s F&A rate. Only the purchase of new equipment for the project using non-federal funds may qualify.

VI. Required Approvals & Workflow

Because cost sharing represents a redirection of University resources, the following approvals are required before submission in Streamlyne:

• Department Chair & Dean: Must approve the source of funds (e.g., departmental budget) and confirm that the cost sharing will not interfere with the PI’s other academic duties.
• Senior Vice Provost for Research (SVPR): Must approve any "special or unusual" cost sharing or requests for central University funds.
• Timing: Requests for central matching funds must be submitted to the Office of Research at least two weeks prior to the submission deadline.

VII. Documentation and Reporting

Once an award is accepted, the Office of Research and the PI are responsible for:

1. Tracking: Ensuring expenses are charged to the correct cost-share companion account.
2. Certification: Certifying effort via the University’s effort reporting system.
3. Audit Readiness: Maintaining records of third-party contributions, including valuations of in-kind services.

VIII. General Restrictions

• No Double Counting: Funds committed as cost sharing for one project cannot be used for another.
• Federal-to-Federal: Federal funds received by NJIT cannot be used as a match for another federal program unless specifically authorized by federal statute.

Administrative Costs: Costs normally treated as F&A (e.g., clerical support, office supplies) generally do not qualify as cost sharing.

I. Policy Summary

Authorization to lead sponsored programs at NJIT is granted to individuals with a primary, full-time employment nexus to the University. This policy ensures that the Principal Investigator (PI) has the requisite authority to commit NJIT resources and ensure compliance with federal, state, and private sponsor regulations.

II. Policy Purpose

To establish criteria for PI eligibility that satisfy Uniform Guidance (2 CFR § 200.308) regarding the management of federal awards and to ensure institutional fiscal and ethical oversight.

III. Policy Scope and Applicability

This policy applies to all NJIT Colleges/Departments, and all externally funded sponsored programs (Federal, State, and Private).

IV. Definitions

• Principal Investigator (PI): The primary individual responsible for the scientific/technical direction of the project and the fiscal stewardship of awarded funds in compliance with 2 CFR 200.
• Key Personnel: Individuals who contribute to the scientific development or execution of a project in a substantive, measurable way.
• Uniform Guidance (UG): Federal framework (2 CFR 200) governing the administrative requirements, cost principles, and audit requirements for federal awards.

V. PI Eligibility Criteria

A. Standard Eligibility (Federal and General Standards)

Full-time Tenured/Tenure-track Faculty, University Lecturers, and Research Professors are automatically eligible to serve as PIs. They must maintain a continuous appointment for the duration of the project period.

B. Student-Led Proposals

In alignment with federal fellowship standards:

• Students cannot serve as independent PIs.
• A full-time Faculty member must serve as the Administrative PI for all student-led research (e.g., NSF GRFP, NIH F31).
• The Faculty PI is legally responsible for the student’s compliance and fund management.

C. State Funding Exceptions (New Jersey State Standards)

For proposals submitted to NJ State Agencies (e.g., NJDOT, NJDEP, NJDOL):

• PIs must ensure that their "Effort Reporting" aligns with specific State-mandated audit requirements, which may be more restrictive than Federal UG.
• If a project involves State-funded cost-sharing, Prior Written Approval and fund verification via a Restricted Account are mandatory before the PI may submit the proposal.

D. Exceptions for Part-Time/Adjunct Personnel

Requests for PIs not meeting standard criteria require an Exception Request.

• Authorization: Must be approved by the Senior Vice Provost for Research.
• Criteria: Must demonstrate a long-term commitment to NJIT and provide a "Sponsoring Departmental Memo" where the Chair guarantees space and administrative support if the part-time PI leaves the institution

VI. Roles and Responsibilities: The "Four Pillars" of Approval

When a Chair, Center Director, or Dean signs off on a proposal in Streamlyne, they are certifying four critical institutional commitments:

VII. Procedures

1. System Access: All proposals must be routed via Streamlyne.
2. Validation: SRA will verify PI eligibility upon the creation of a Proposal Development (PD) record.
3. Conflict Resolution: Questions regarding eligibility or "PI Status Exceptions" should be directed to the Director of Sponsored Research Administration.

Related Policies

• NJIT Policy 2.2: Submission of Sponsored Project Proposals
• NJIT Policy 2.4: Sponsored Projects Budget Preparation
• 2 CFR 200: Uniform Administrative Requirements