by Dana deMink & Kayley Cusack, OSP
When it comes to award transfers it is important to remember that whatever the situation (either the award transferring to MSU or going from MSU to another institution) awards are made to institutions and not to principal investigators. Therefore, when a faculty transfers to MSU from another institution, any on-going projects must be relinquished by their previous institution before they can be transferred to MSU. Likewise, when a faculty member leaves MSU, their MSU Chair must approve the relinquishment of any current award and related equipment to the PI's new institution.
Both institutions need to make important relinquishment decisions such as:
- Will the grant be transferred, or will a new PI be named to take over the project?
- Are any project staff or graduate students working on the project transferring to the new institution or will they continue at the current institution with a subaward issued back to the original institution?
- Is there equipment that will need to be transferred?
- Is there a lab that will need to be closed out?
- Are there subawards on the current award that need to be closed-out or terminated?
- What is the relinquishment date?
- What is the unobligated balance?
- Are there any cost share requirements that need to be met?
- Has intellectual property been developed that needs to be protected?
- Are there contractual considerations that the new home institution may find difficult to accept?
- Are there compliance protocols to be put in place or closed out?
The transfer of an award from one institution to another can take from as quick as 90 days to over a year to accomplish. If you are looking for “how-to” information on MSU's transfer process, please visit our new OSP webpage that provides more detail about the procedure.
Once the decision to transfer has been made, the sponsor must approve the transfer. The process for transfer requests is defined by each sponsor. Many federal agencies have published information on their respective transfer processes. What follows is high-level information regarding the transfer process for a few of our federal sponsors.
NIH
NIH prior approval is required for the transfer of administrative responsibility for a grant-supported project from one entity to the other. It is important to let NIH know of transfer requests as soon as possible – in fact NIH recommends the PI and administrative staff begin the formal transfer of a grant at least 60 days in advance of a PI's move to a new organization.
NIH advises PIs to contact their Program Officer to discuss their transfer. Provided there are no concerns about this change to the award, NIH advises the PI to then contact the Grants Management Specialist (GMS) assigned to the award. The GMS will assist with questions as well as provide support with the required documentation to process this change request.
NIH refers to a transfer of a grant award to a different organization as a "Change of Recipient Organization” request. The original grantee must prepare and submit a relinquishing statement and the receiving institution must submit an application via Grants.gov using the Change of Recipient Organization Opportunity. This can be found on the Parent Funding Opportunity Announcement page under Post-award Administrative Action Announcements.
As mentioned earlier, equipment purchases are always a consideration when grants are transferred. Equipment is typically considered as a part of the original grantee's relinquishment. If not a part of the relinquishment, NIH will reserve the right to transfer equipment to the new institution. For additional information see NIH's Property Management System Standards.
NIH staff will consider whether the facilities and resources of the new location will meet the needs of the research objectives and will review whether the move will impact project expenditures.
One other concern with NIH transfers is mid-year vs. anniversary date transfers and budgeting accordingly. Discuss this with your OSP representative.
NSF
When a PI plans to leave an organization during the course of an award, the PI or the SPO, shall notify the cognizant NSF Program Officer. If the project is to continue with the original organization, the cognizant NSF Program Officer should advise the recipient to nominate a substitute PI. If the project is to be continued at the PI's new organization, and if NSF and both organizations agree, formal notification of the impending transfer can be electronically initiated by either the PI or the PI's organization. The amount transferred has to be equal to or less than the unobligated balance.
The original organization concurs with the transfer of the award by electronically forwarding the request to the new organization in Research.gov or Fastlane (Note: Fastlane is transitioning to Research.gov and will soon be removed as an option).
The new organization completes the request by providing a detailed budget for the transfer amount agreed to by both organizations. The AOR of the new organization must sign and submit the request via use of NSF's electronic systems. Submission of the request constitutes agreement by the new organization to assume responsibility for completion of the project effort and to administer the award (as originally awarded) from the transfer date to completion in accordance with any special terms and conditions and the applicable general terms and conditions that normally govern NSF awards made to the new organization. Special terms and conditions, as appropriate, cited in the original award will apply to the new recipient organization.
NSF will assign a proposal number at the time of submission. This proposal number will become the new award number when the transfer is approved by an NSF Grants and Agreements Officer. For additional information, see section B.2.f. of NSF's Award Administration guide.
DOE
DOE defines three acceptable scenarios to address a PI exiting a university and moving to another university. In the first option, the university requests approval for DOE to assign a new PI to the award at the same university. A formal, written request must be sent to the Contracting Specialist for the award. The request should include a rationale/justification for the change in Principle Investigator. In the second option, when investigators move to new institutions, DOE typically approves funding reassignment through a sub-award arrangement with the original institution. For this option, supporting documents, budget, budget justification, revised scope, and a justification for why the project can still be successful is required. For projects close to completion (this is the third option), DOE also encourages a PI to get approval from their original institution to maintain an adjunct position with the university. Since these appointments typically last under a year, this would be used in projects that are close to completion.
NASA
Any administrative change such as Principal Investigator changes, scope modifications, no-cost extensions, etc. should be submitted as a request in writing to the Grant Officer listed on the award's NF 1687.
USDA-NIFA
Project Directors must contact the NIFA program staff associated with the existing award (Program Point of Contact is identified in Block 4 of Form NIFA-2009, Award Face Sheet) to facilitate the transfer of a grant from one institution to another institution. The transfer request must be submitted to the NIFA program staff by the existing awardee organization.
- A letter from the authorized organizational representative (AOR) (the letter must be signed by the AOR) addressed to the NIFA program staff identifying that the awardee institution is relinquishing the remaining funds on the grant.
- A final Form SF-425 (Federal Financial Report), the amount noted on Field 10.p (Field 10 if using the short form) of the final SF-425 reflects the total amount of funds remaining on the grant. This would be the amount available to transfer to a different institution.
The NIFA program staff will provide a request for application (RFA) to the institution identified as the potential recipient of the remaining funds. The RFA will include instructions such as how to access the application package (including necessary forms and the "NIFA Grants.gov Application Guide"), complete the appropriate forms, and where and how to submit the forms.
DOD
Any change in a key person identified in the award cover page will require prior approval. The Grantee institution must appoint a replacement PI with the approval of the Grants Officer or relinquish the grant in accordance with DoDGARs 32.61.
