Sponsored Projects Administration

REQUIREMENTS

Please send a notification email to SPA Pre-Award as soon you know that a PI is joining (Transfer In) or leaving the university (Transfer Out).

In accordance with NIH Policy 8.1.2.7, 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 (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 recipient has agreed to relinquish responsibility for an active project before the completion date of the approved project period. This includes any proposed change of recipient 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.

A change of recipient request normally will 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. NIH will also consider the length of time, the percentage of funds, and the amount of work remaining in the project period. A change may be made without peer review, provided the PD/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 IC may require peer review or may disapprove the request and, if appropriate, terminate the award.

NIH expects both the relinquishing and applicant organizations to disclose whether a Change of Recipient Organization is occurring within the context of an ongoing or recent investigation of misconduct of any kind, including but not limited to professional misconduct or research misconduct or is related to concerns about safety and/or work environments (e.g. due to concerns about harassment, bullying, retaliation, or hostile working conditions) involving the PD/PI. NIH will in turn be better positioned to enable informed grant-stewardship decisions regarding matters including, but not limited to, substitute personnel and institutional management and oversight.

 The transfer application should be submitted prior to the anticipated start date as significant delays in processing may occur. The transfer process can range from 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.
  • In consultation with Pre-Award, PI/department works on the transfer application(s) immediately, gathering original grant documents (applications & notice of awards), submitting applicable protocols 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 in UTSTART for submission by SPA.

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.

RELINQUISHING PACKET (FROM THE ORIGINAL GRANTEE)

A change of recipient organization request must be made before the anticipated start date at the new organization and Pre-Award, preferably several months in advance. Failure to provide timely notification may result in disapproval of the request or significant delays in processing. Recipients are encouraged to discuss any potential issues with the awarding IC(s) prior to submitting a change of recipient organization request. If requesting a transfer in the middle of a budget period or at the end of the Federal fiscal year, recipients should contact the awarding IC for IC-specific guidance on the timing and preparation of the change of institution application.

A request for a change of grantee organization must be submitted by the relinquishing institution in eRA Commons and should include:

  • Official Statement Relinquishing Interests and Rights in a Public Health Service Research Grant (PHS 3734) (relinquishing statement)
  • Final Invention Statement (Form HHS 568)
  • Final FFR (Expenditure Data)

TRANSFER APPLICATIONS (SUBMITTED BY UTHEALTH FOR INCOMING GRANTS)

UTHealth SPA contact for incoming grant transfers is Caroline Dietz

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.

 NIH Transfer applications are submitted via UTSTART to Grants.gov using the Parent Funding Opportunity Announcement: Change of Recipient Organization (Type 7 Parent Clinical Trial Optional).

The following documents should be submitted to Pre-Award to facilitate submission of a transfer application to the NIH or agency:

  • Completed Transfer In Information Sheet to include all projects
  • Each transfer application will be submitted as an individual proposal record in UTHealth Start and must adhere to guidelines within the Grants Policy Statement, the SF424 Application Guide, the Transfer Application-specific FOA, and the original FOA of the grant that the transfer application is for. In UTHealth Start, the Proposal Type should be “Transfer”

    Within each transfer record include:

Uploads and Reviews

  • Current year award document from NIH
  • Relinquishing statement
  • Copies of the original grant application submitted to the agency.
  • IRB/IACUC/IBC/RSC/SCRO approvals
  • Any correspondence with the NIH regarding the transfer
  • If applicable, updated subcontract documents (scope of work, LOI, budget & justification).

 SF424 R&R Cover Page

  • Box 4a must contain the federal identifier of the grant to be transferred (IC+Serial number)
  • Box 8. Type of Application should be “Revision”-E. Other “Change of Recipient Organization”

Performance Site: List any performance sites

SF 424 (R&R) Other Project Information

  • Abstract, Project Narrative, References, updated as necessary
  • Updated Facilities & Other Resources page, including probable effect of the move on the project
  • Updated Equipment: Detailed list of any equipment purchased with grant funds to be transferred to the new organization (inclusion of this list in the transfer application from the new organization indicates its acceptance of title to that equipment)
  • Other Attachments: Certification of IRB (name document “IRB Documentation.pdf”) and/or IACUC approval (name document “IACUC Documentation.pdf”)

*Inclusion of these approvals will expedite the transfer process*

Personnel: SF 424 Research & Related Senior/Key Person Profile

  • Updated biographical sketches for the PD/PI and existing senior/key personnel
  • Biographical sketches for any proposed new senior/key personnel,
  • Updated Other Support for senior/key personnel
  • All senior/key personnel must have a valid eRA Commons Username

Budget (Instructions are generalized for R project codes, further guidance available in Transfer FOA for other award types)

  • The start date must be a future date and budget periods are within the original budget periods stated on the most recent Notice of Award
  • The R&R Detailed Budget form must be used, regardless of the form used for the initial application for current award for all research and career mechanisms. The budget should be based on the direct costs relinquished by the original grantee organization, unless otherwise instructed by the awarding IC.
  • Even if the budget for the original award was submitted in a modular format, the R&R Detailed Budget form must be used for an electronic application for change of grantee organization. For these awards, grantees may either complete all of the fields in the R&R Detailed Budget as appropriate or, they may 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 8-10, and Section H (Indirect Costs). *A full detailed budget is recommended to expedite award setup*
  • In General, transfers on an anniversary date will utilize direct costs as committed on the previous year’s NoA plus applicable F&A costs as a basis for budgeting. Mid-year transfers will utilize the relinquished direct costs on the relinquishment statement plus applicable F&A costs for the first year. The future years will utilize the direct costs committed on the previous year’s NoA plus applicable F&A costs. If there are extenuating circumstances, the awarding IC will determine if direct costs or total costs should be utilized as a basis for budgeting.
  • Preaward costs: A recipient may, at its own risk and without NIH prior approval, incur obligations and expenditures to cover costs before the beginning date of a transfer award. The recipient may do so only if those costs are necessary to conduct the project and would not require prior approval if incurred under an awarded grant. For the purposes of Pre-Award costs, transfers are treated like non-competing continuation awards. Therefore, the Pre-Award costs incurred are not limited to 90 days prior to the beginning date of the initial budget period of that transferred award to the new recipient organization.

Research Plan

  • Introduction: Include statements to address the following (required):
    • Indicate whether the overall research plans/aims have changed from the original submission
    • Indicate whether the change of recipient institution is related to concerns about safety and/or work environments (e.g. due to concerns about harassment, bullying, retaliation, or hostile working conditions) involving the PD/PI.
    • Indicate whether the change of recipient institution is occurring within the context of an ongoing or recent investigation of misconduct of any kind, including but not limited to professional misconduct or research conduct
  • Research Strategy: If transferring on the anniversary date, include the progress report for the current year that includes a statement regarding the goals for the upcoming year. If transferring during the budget period (i.e., a mid-year transfer), contact the awarding IC to determine if a progress report is required. If required, the progress report should be included in the page limits of the Research Strategy section.

Human Subjects/CT

  • Other Requested Information: Include a statement indicating whether the study records have changed from the original submission as an Other Requested Information attachment. If the study records have changed, provide that updated information as new study records. If the study records have not changed, provide the original study records and/or delayed onset study records. 

Supplement

  • Question 6: Change of Investigator/Change of Institution Section: Check this box if your application reflects a change in grantee institution from that indicated on your previous application or award. Enter the name of the former institution if this application reflects a change in grantee institution.

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.

COMPLETION OF THE TRANSFER PROCESS

NIH will accomplish a change of recipient organization by issuing a revised NoA to the original recipient reflecting 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 or the available balance in PMS, whichever is less.

Concurrently, the new recipient will receive the NoA reflecting the direct cost balance reported on the relinquishing statement plus applicable F&A costs, if funds are available. If the change of recipient organization occurs on the anniversary date of the project, the NoA to the new recipient will reflect the previously committed direct cost level plus applicable F&A costs if funds are available. If the change of recipient organization occurs during the course of the budget period, the policy of the awarding IC will determine if the NoA to the new recipient will reflect the direct cost relinquished by the former recipient plus applicable F&A costs or the total costs relinquished by the former recipient. This amount is subject to change as a result of the closeout of the original grant and may be adjusted downward.

Unobligated Balances: The process to release an unobligated balance requires that the relinquishing institution submit the FFR to the NIH. Once the NIH accepts the FFR the Office of Financial Management will reconcile financial statements and issue an Unobligated Balance letter to the new recipient institution in order to transfer the unobligated balance. This process can take 6-12 months.

INCOMING GRANT TRANSFER PROCESS FOR NON-NIH AGENCIES 

Many agencies will allow grant transfers. The following guidelines should be followed for incoming non-NIH grant transfers:

  • Completed Transfer In Information Sheet to include all projects
  • Each transfer application will be submitted as an individual proposal record in UTSTART (generally as a Manual, non-S2S type) and must adhere to guidelines within the agency-specific guidelines and the original FOA of the grant that the transfer application is for.

Within each transfer record include:

  • Current year award document
  • Relinquishing statement
  • Copies of the original grant application submitted to the agency.
  • Any correspondence with the agency regarding the transfer including guidelines
  • IRB/IACUC/IBC/RSC/SCRO approvals
  • If applicable, updated subcontract documents (scope of work, LOI, budget & justification)
  • Transfer application with budget and Justification with subaward budgets included, as applicable

GUARANTEE REQUEST FOR A TRANSFER IN APPLICATION

In order to limit retroactive personnel actions and cost transfers by allowing expenditures to be charged to the correct fund source, Guarantee accounts may be set up for incoming transfers 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.

  • For grants that will be transferred to UTHealth where the UTHealth PI is the contact PI and the UTSTART transfer application has not been submitted, contact Caroline Dietz
  • For incoming subawards that will be transferred, the UTSTART record must be reviewed and approved by SPA before a Guarantee is requested via UTSTART

TRANSFER OUT PROCESS 

UTHealth SPA contact for outgoing grant transfers is Carmen Martinez

When a researcher resigns or retires from the University, there must be a plan for orderly transfer or closure of all research responsibilities. When the separating researcher is a Principal Investigator, there are additional activities that must be completed. The goals of the process are:

  1. To transfer or terminate sponsored projects in accordance with the funding agency guidelines, whether federal, state or private.
  2. To ensure continued safety and care of animals in research studies.
  3. To ensure continued safety and care of human subjects in research studies.
  4. To ensure institution assets are accounted for.
  5. To ensure that hazardous agents (e.g. chemicals, biological agents and radioactive materials) as well as contaminated equipment are properly disposed of or decontaminated.
  6. To ensure oversight of research data is transferred or retained appropriately.
  7. To ensure that FDA INDs, FDA IDEs, and ClinicalTrials.gov records are properly closed out or transferred according to federal regulatory requirements.
  8. To ensure that research involving human ESCs or IPSCs is closed out or transferred to another UTHealth investigator.
  9. To ensure that issues related to technology management are addressed and any current COI plans are terminated.

The separating Principal Investigator and the department chair or designee must complete the PI Separation Checklist. The completed, signed PI Separation Checklist will then be utilized to initiate the relinquishment of projects or begin the prior approval process to administratively transfer the project to a new individual.

For questions related to the transfer in/transfer out process, contact SPA PreAward Team