Hi, folks. I'm a recent subscriber to this list and have been enjoying reading your comments for a couple months now. I'm new to Grants business, but was a Corporate Paralegal in a former life.

My (persona)l opinion is that if the definition of a Principal had been intended to include Trustees, it would have specifically done so, and would have put them at the top of the list. The list is certainly inclusive. The first position specified  is
"officer" and the list of other possible principles seems to decline in level of responsiblity from there. I don't think a Trustee would be considered to have "primary management or supervisory responsibilities" or ""critical influence on or substantive
control over" those transactions that a PI or Researcher would have control over. I think the buck stops (or is intended to stop) with the officers.

Feel free to tell me I'm wrong...

Roberta

Roberta Truscello
Pre Award Specialist
The College of New Jersey
Ewing, New Jersey
609-771-1765
xxxxxx@tcnj.edu

William Campbell wrote:

> RESADMers, a colleague at another institution asked me the following question.  I don't know the answer, does anyone?
>
> Under the "Debarment and Suspension" compliance requirement, does a member of an institution's Board of Trustees meet the definition of "principal"?
>
> Here's what he knows so far:
> Definition of Principal (from NIH and NSF legislation incorporating the
> requirement):  Principal. Officer, director, owner, partner, key employee, or other person within a participant with primary management or supervisory
> responsibilities; or a person who has a critical influence on or substantive control over a covered transaction, whether or not employed by the participant. Persons who have a critical influence on or substantive control over a covered transaction are:
>     (a) Principal investigators.
>     (b) Researchers.
>
> Please answer to the list or to me, your choice.  I'll pass the responses on.
>
> Regards, Bill
>
> Bill Campbell
> Director, Grants & Research
> University of Wisconsin-River Falls
> 715/425-3195
> xxxxxx@uwrf.edu
>
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