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.