I recently received an email from a department administrator that NSF rules have been changed (link here), such that all investigators must fill out a conflict of interest (COI) form. They then go on to list a cadre of examples which meet the definition of investigator and a statement that all investigators must fill out this form. Our university has the definition of investigator here.

My question is, are graduate students typically considered investigators by the NSF? If so, we certainly do not receive the recognition that PIs and other listed investigators get.

  • Based on your links, it seems clear that grad students may be investigators, but that the exact determination of who is an "investigator" depends on the nature of the person's duties (whether they have a "degree of independence"). That suggests that this is a question for which you need a specific answer from someone at your own university or in your own department, probably either the PI on any grant you are working on, or a staff member who deals with administration of these grants.
    – BrenBarn
    Jan 18, 2014 at 7:35

2 Answers 2


Actually, the NSF, in its Grant Proposal Guide, does not actually define the concept of an "investigator." Instead, it chooses to define the different categories as "senior personnel" and "other personnel." Typically, postdoctoral fellows and graduate students fall under "other personnel."

Personally, in such matters, I would opt on the side of caution and just have the graduate students fill out the conflict of interest form. It doesn't take very long, and having it in place makes life easier for everyone.


PI stands for PRINCIPAL Investigator, i.e. the head investigator. Under this guideline grad students and postdocs ARE still investigators, albeit, not principal ones.


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