Pi and Grant Transfers: Procedures

Who Should Know These Procedures

Dean
Senior Administration – Vice Provosts, Associate Deans

Director, Department Chair, Division Head
Faculty

Departmental/Divisional Administrators

Finance Personnel – Research Accounting, Accounting Services
Grants & Contracts Personnel

Research Compliance Personnel

Research Integrity Personnel

All Employees

Information Technology Personnel

Faculty Affairs Personnel

Students


Contacts

Subject	Contact	Phone	Email
Policy questions	Michelle A. Lewis, MS	[phone]	[e-mail]
Research Accounting questions	Kevin McGrath	[phone]	[e-mail]
Faculty Affairs issues	Mark Albano	[phone]	[e-mail]
Institutional research compliance issues	Barbara Pifel	[phone]	[e-mail]

  
Applicable Federal Regulations


NIH Grants Policy Statement

Part II: Terms and Conditions of NIH Grant Awards
Subpart A: General

Change of Grantee Organization: After WMC determines whether to retain or relinquish the grant, NIH prior approval is required for the transfer of the legal and administrative responsibility for a grant-supported project or activity from one legal entity to another before the expiration date of the approved project period. Such a change of grantee organization may be accomplished under most NIH grants, including construction grants, if:

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  The grant to be transferred has been terminated in accordance with Code of Federal Regulations Sections 45 CFR 74.61 or 92.43. (Provision under 74.61 includes statement that an award may be terminated in whole or in part by the HHS awarding agency with the consent of the recipient or may be terminated by the recipient upon sending to the HHS awarding agency written notification setting forth the reasons for such termination.)
  
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  A noncompeting continuation award that is within an approved project period has been withheld because of the grantee's actions (see "Administrative Requirements—Enforcement Actions—Suspension, Termination, and Withholding of Support"); or
  
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  The original grantee has agreed to relinquish responsibility for an active project before the expiration of the approved project period. This includes any proposed change of grantee as a result of a PI on a research project transferring from one domestic organization to another domestic organization or from a foreign organization to a domestic organization. The project under the same PI may be supported at a new organization for a period up to the remainder of the previously approved project period in an amount not to exceed that previously recommended for direct costs (plus applicable F&A costs) for the remaining period.
  

A change of grantee that involves the transfer of a grant to or between foreign institutions or international organizations requires competitive review and approval of the Institute or Council Advisory Council/Board. Transfer of a grant from a foreign organization to a domestic organization requires the approval of the federal sponsor’s Grants Management Officer.
A change of grantee organization may involve the transfer of equipment purchased with grant funds. The transfer may be accomplished as part of the original grantee's relinquishment of the grant; otherwise, NIH reserves the right to transfer title to equipment to the new organization as indicated in "Administrative Requirements—Management Systems and Procedures—Property Management System Standards."
A request for a change of grantee organization must be submitted to the designated GMO and must be accompanied by a Relinquishing Statement and a Final Invention Statement and Certification from the original grantee as well as an application (PHS-398) from the proposed grantee. If the original award was the result of a modular application, modular procedures also apply to the request for change of grantee. The application (for awards other than those made under modular procedures) from the proposed grantee should include, at a minimum:

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  A face page;
  
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  Budget pages (current and future years);
  
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  An updated biographical sketch;
  
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  A statement indicating whether the overall research plans/aims have changed from the original submission, and, if so, providing updated information;
  
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  An updated "other support" page(s), if necessary;
  
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  A resources page;
  
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  A checklist page;
  
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  Certification of IRB/IACUC approval, if applicable; and
  
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  If the change includes the transfer of equipment purchased with grant funds, the application must include a detailed list. This list, as part of a transfer application, serves as an acceptance of title by the new organization. NIH may request additional information necessary to accomplish its review of the request.
  

For a modular application, the proposed grantee must submit the following:

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  A face page;
  
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  Narrative budget information, including total direct costs and F&A costs for the current budget period;
  
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  Biographical sketches for key personnel;
  
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  "Other support" pages;
  
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  Resource page;
  
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  Checklist page; and
  
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  If future budget periods remain, information regarding the number of modules and the basis for computing F&A costs.
  

A change of grantee organization request must be made prior to the anticipated start date at the new organization and preferably several months in advance. Failure to provide timely notification may result in disapproval of the request or a delay in processing.
A change of grantee request will normally be permitted only when all of the permanent benefits attributable to the original grant can be transferred, including equipment purchased in whole or in part with grant funds. In reviewing a request to transfer a grant, NIH will consider whether there is a continued need for the grant-supported project or activity and the impact of any proposed changes in the scope of the project. A change may be made without competitive review, provided the PI plans no significant change in research objectives and the facilities and resources at the new organization will allow for successful performance of the project. If these conditions or other programmatic or administrative requirements are not met, the NIH awarding office may require a competitive review or may disapprove the request and, if appropriate, terminate the award.
As stated above, the original grantee must provide a written statement relinquishing its interests and rights to the grant in accordance with instructions from the NIH awarding office. Acceptance of a Relinquishing Statement by NIH does not guarantee approval of a transfer application for the continued funding of a project.
NIH will accomplish a change of grantee organization by issuing a revised NGA (Notice of Grant Award) to the original grantee, which will reflect the revised budget/project period end dates, deletion of any future-year support, and deobligation of remaining funds, if applicable. (A deobligation of funds will be based on the estimated grant expenditures through the relinquishment date, as determined from the Relinquishing Statement.) Concurrently, the new grantee will receive an NGA reflecting the balance reported on the Relinquishing Statement or, if the change of grantee organization occurs on the anniversary date of the project, the NGA to the new grantee will reflect the previously committed direct cost level plus applicable F&A costs. This amount is subject to change as a result of the closeout of the original grant and may be adjusted downward.