In accordance with NIH Policy 126.96.36.199, NIH prior approval is required for the transfer of the legal and administrative responsibility for a grant-supported project or activity from one institution to another before the expiration of the approved project period (competitive segment). A change of grantee organization may be accomplished under most NIH grants, including construction grants, if any of the following conditions are met:
- 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 PD/PI on a research project transferring from one organization to another organization. The project under the same PD/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.
- The grant to be transferred has been terminated in accordance with 45 CFR part 74.61 or 92.43.
- A non-competing 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).
A change of grantee request submitted to NIH 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.
The transfer process can range from a sixty (60) days to several months. To expedite this process ensure that:
- The PI/department notifies the agency of the transfer and maintains an open communication with the relinquishing school to ensure timely submission of the relinquishing packet.
- PI/department works on the transfer application immediately, gathering original grant documents (applications & notice of awards), submitting applicable applications to obtain approval for all assurances on the project.
- The PI completes all the required investigator training, and drafts the document required for the transfer application.
NIH requires a relinquishing package from the original institution and a transfer application from the proposed grantee. The PI should notify their NIH Grants Management Officer and inquire about any additional information that should be included in the transfer application.
A change of grantee organization request must be made before 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 significant delays in processing.
A request for a change of grantee organization must be submitted to the GMO and should include:
- Relinquishing Statement (PHS 3734).
- Final Invention Statement (Form HHS 568).
- Final FSR (expenditure data).
The PI/department should submit the transfer application to Pre-Award for review and approval. Allow approximately ten (10) business days for transfer application review. Transfer applications are submitted via Grants.gov using the Parent Funding Opportunity Announcement.
The following documents should be submitted to Pre-Award prior to submission of transfer application to agency:
- Complete and signed R&A form.
- Complete copy of the electronic or paper transfer application as specified below.
- If applicable, subcontract documents (scope of work, LOI, budget & justification, F&A rate agreement and a Conflict of Interest Disclosure form from each subcontractor).
- Copies of the original grant application submitted to the agency.
- Copies of the relinquishing statement including the listing of equipment to be transferred.
- Copy of the Final Invention Statement.
- Current year award document from NIH.
- SF 424 (R&R) Cover Component.
- SF 424 (R&R) Project/Performance Site Location(s).
- SF 424 (R&R) Other Project information:
- Certification of IRB/IACUC approval, including OHRP and OLAW assurance numbers, if applicable.
- Facilities and Other Resources, including probable effect of the move on the project.
- Detailed list of any equipment purchased with grant funds to be transferred to the new organization (inclusion of this listing the transfer application from the new organization indicates its acceptance of title to that equipment).
- SF 424 Research & Related Senior/Key Person Profile:
- Updated biographical sketches for the PD/PI and existing senior/key personnel and biographical sketches for any proposed new senior/key personnel, and updated "other support" page(s) as necessary.
- Budget pages applicable for activity code (current and future years). If the budget for the original award was submitted in a modular format, use the R&R Detailed Budget form for all electronic applications. Grantee may either complete all of the fields in the R&R Detailed Budget as appropriate or complete only the costs for the PD/PI (Section A), and include the remainder of the direct costs under Section F (Other Direct Costs) Item 8, and Section H (Indirect Costs). (For awards resulting from modular applications, include narrative budget information for the current budget period, including total direct cost and the basis for computing F&A costs and, if applicable, future budget periods.) Budgets should not exceed the direct costs previously recommended for direct costs (plus applicable F&A costs) for any budget period. For transfers during the course of a budget period, the budget for the initial year may be based on the total costs relinquished only if the grantee has been instructed to do so by the awarding IC.
- PHS 398 Research Plan.
- If transferring on the anniversary date, include the progress report for the current year including a statement regarding the goals for the upcoming year. For all transfer applications include also a statement indicating whether the overall research plans/aims have changed from the original submission, and, if so, provide updated information.
- PHS 398 Cover Page Supplement.
- PHS 398 Checklist.
NIH may request additional information necessary to accomplish its review of the request. 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 Notice of Grant Award (NOGA) 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. Any deobligation of funds will be based on the estimated grant expenditures through the relinquishment date, as determined from the relinquishing statement. Concurrently, the University will receive an NOGA reflecting the balance reported on the Relinquishing Statement or, if the change of grantee organization occurs on the anniversary date of the project, the NOGA to the University will reflect the direct cost level, plus applicable F&A costs, previously committed.
In order to limit retroactive personnel actions and cost transfers by allowing expenditures to be charged to the correct fund source, accounts may be set up for new and renewal projects prior to receiving official notification of the award. Schools/departments requesting early account set up do so at their own risk. If funding does not materialize after an account is set up, the expenses will be transferred to an eligible account. If effort reports have been certified, expenses may only be transferred to a departmental or discretionary account. Refer to the Guarantee Accounts page for more information.