At UCLA, we are formulating our campus policy and procedures to implement
NSF's Conflict of Interest requirement (and soon, PHS).    We are currently
discussing the definition of investigator in order to determine who will
need to complete disclosure forms.

The NSF policy defines an investigator as a " PI, Co-PI, or any other person
at the institution who is responsible for the design, conduct, or reporting
of research or educational activities funded or proposed for funding by
NSF."   The current PHS version has similar wording.   We are leaning toward
requiring submission of disclosures from all PIs and Co-PIs involved in a
project, but not other project personnel.   This interpretation is based on
the fact that we define the PIs and Co-PIs as being the individuals
*responsible* for the design, conduct, and reporting on the project.    We
would appreciate knowing the plans that other institutions have in this
regard.   Are you including just PIs and Co-PIs, or other personnel as well?
 If you include others, what mechanism do you plan on using to identify and
track these other individuals?

I will be glad to post a summary of responses to this list.  My email
address and other contact information is listed below.   Thanks!   -- Pamela
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Pamela A. Webb, Assistant Director
UCLA Office of Research Administration
Phone:  (310) 825-2205
Fax:  (310) 206-4996
Email:  xxxxxx@ocga.ucla.edu
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