Division of Research
Transition Guidance for Incoming Faculty PIs
Tools for New Faculty PIs
The Division recommends that all incoming faculty members complete this checklist for incoming principal investigators (PIs), a Google form that provides guidelines and recommendations for individuals new to Brown.
This spreadsheet, which can be converted to a Google Sheet and shared with your contacts on the Sponsored Projects team, will help you keep track of the actions required for each award transfer.
Individuals who are not automatically eligible for PI status by virtue of their appointment type must submit this form to the appropriate institutional officials and be approved for PI status before submitting contract and grant proposals and applications to external funding sources.
Incoming Award Transfers
Award transfer policies can vary, so it is important for incoming faculty members to review guidance for the agency sponsoring their award. The Division of Research provides award transfer process guidelines below for the National Institutes of Health (NIH) and National Science Foundation (NSF).
The NIH recommends that a PI begin the formal process of requesting the transfer of a grant at least 60 days in advance of their move to a new organization.
The first step in this process is to contact the NIH program officer to discuss the feasibility of the transfer. If no concerns are raised by your program officer, contact the sponsoring agency’s grants management specialist assigned to the award. They can assist with questions about the submission of required documentation, such as the relinquishing statement and transfer application.
The process of transferring a grant or grant application to a different organization is known as a "Change of Recipient Organization” request. Informational materials are required from both the original recipient and the proposed new recipient. Further information is available in the NIH Grants Policy Statement, under Prior Approval Requirements.
NIH Award Steps for Incoming Faculty
- Incoming Brown faculty should ensure that their previous institutions complete and submit relinquishing statements as early as possible.
- The PI then submits a transfer application from Brown, per the institution’s instructions. Because different institutions require differing information in transfer applications, the transfer application should be based on guidance provided by the grants management specialist.
- After the transfer is approved and Brown is issued a notice of grant award (NoA) by the sponsor, a spending account is created.
- Unlike other types of funding, incoming transfer awards from the NIH generally do not require sponsor approval for spending more than 90 days before the budget period start date. This allows faculty to begin spending earlier on the project without waiting for the official transfer award. If the PI intends to begin spending before the transfer award has arrived, an advance account is recommended.
NIH Subaward Transfer
If the transferred award has subaward collaborations with other organizations, those subrecipients should be notified that their subaward agreement is ending and, if applicable, will be reissued once the grant award has been transferred to Brown University. These notifications should be sent out from the PI’s previous institution to the central offices at the collaborating institutions as soon as the PI confirms the plan to transfer the award.
The relinquishing statement and transfer application rely on budgeting information that can only be finalized once each subrecipient has submitted their final invoice to the original institution. To ensure an efficient transfer of the subaward agreement once the NIH transfer is completed, please contact your department’s Research Subcontracting grant and contract administrator and please identify the anticipated subrecipient organizations so that Research Subcontracting may advise on how to begin the subrecipient monitoring process.
Further information on the Change of Recipient Organization is also available in the Prior Approval Requirements section of the NIH Grants Policy Statement.
Administrative Review
NIH award transfers are not guaranteed. Once the transfer documentation is received, the NIH grants management and program staff conducts an administrative review of the request to determine if the transfer is appropriate, and to determine the level of NIH funding that will be awarded to the new recipient. The decision to authorize transfer of the grant is based on the following criteria:
- The project has been relinquished by the original organization.
- The facilities and resources at the new location allow for the successful performance of the project.
- The investigator plans no significant changes in research objectives and level of expenditures from those described in the previously approved project.
When a PI plans to leave an organization during the course of an NSF grant, the organization can choose to nominate a substitute PI or request that the grant be terminated and closed out. In those cases where the PI’s original and new organizations agree, the NSF will facilitate a transfer of the grant and the assignment of remaining unobligated funds to the PI’s new organization.
NSF Award Steps for Incoming Faculty
- After Brown receives the PI transfer request from the previous institution on Research.gov, staff complete the request by providing a detailed budget, if requested, for the transfer amount agreed to by both organizations.
- A record is created in Brown’s grants management system by the PI’s new department at Brown, ensuring that the budget total matches the incoming award amount
- Upon approval of the system record, Brown’s authorized organizational representative (either Sponsored Projects or the BioMed Research Administration) electronically submits the PI transfer request on Research.gov.
- The NSF assigns a proposal number when the PI transfer request is submitted. This proposal number becomes the new grant number when the transfer is approved by an NSF grants officer
- Upon receipt of the necessary materials, the NSF reviews the request and, if approved, deducts the specified transfer amount from the original grant and re-establish it under a new grant number at the new organization. Award notification by the NSF grants officer constitutes NSF approval of the grant transfer. The award notification also specifies the applicable general terms and conditions that govern the grant
- After the transfer is approved and Brown is issued a NoA by the sponsor, a spending account is created.
Monetary Discrepancies
Upon transfer of the grant to the new organization, any monetary discrepancies must be resolved between the original and the new grantee. The NSF will not intervene in any disputes between the two organizations regarding the transferred amount. For this reason, it’s extremely important to ensure that the amounts reflected on the PI transfer request match the final expenditure totals.
NSF Subaward Transfer
Although most collaborations under NSF awards are awarded separately and directly from NSF to each collaborating organization, if the PI’s NSF award does include a subaward collaboration, then the subrecipient should be notified that their subaward agreement is ending and, if applicable, will be reissued once the grant award has been transferred to Brown University. These notifications should be sent out from the PI’s previous institution to the central offices at the collaborating institutions as soon as the PI confirms the plan to transfer the award. The subrecipient’s final invoice will be required before submitting final expenditure totals. The transfer application relies on budgeting information that can only be finalized once each subrecipient has submitted their final invoice to the original institution.
To ensure an efficient transfer of the subaward agreement once the NSF transfer is completed, please contact your department’s Research Subcontracting grant and contract administrator and please identify the anticipated subrecipient organizations so that Research Subcontracting may advise on how to begin the subrecipient monitoring process.
Equipment Transfer
Equipment purchased with NSF funds for use in a specific project should remain available for use for the duration of the project. PIs who are in the midst of projects that included funding for equipment and who will continue the project at a new organization with NSF support should arrange with their original organization to have the equipment transferred with them. Shipping costs for such equipment may be charged to the original or transferred grant as an allowable cost. Budgets should not include funds to “buy” equipment that had been previously obtained with federal funds.
Alternative Options
When the amount of time and funds remaining in a project are modest, and if both the original and new organizations are in agreement, the original organization may issue a subaward to the new organization instead of initiating a full award transfer. This and other possible alternatives should be discussed with the NSF grants officer.
For awards funded by other federal agencies (e.g., NASA, U.S. Department of Defense, U.S. Department of Energy), the transfer guidelines tend to differ by award type, so contact your program officer to determine the best way to proceed.
Most nonfederal award agreements will indicate whether awards can be transferred to a new organization. Please contact the Sponsored Projects team for assistance interpreting sponsor requirements.
Submitting Proposals Before Arrival at Brown University
When an incoming faculty member intends to submit a grant proposal in advance of their start date at Brown, it is often most efficient for the proposal to be submitted by Brown, as opposed to submitting through their prior institution and transferring the future award. Per Brown’s PI Eligibility Policy, new tenure-track faculty become eligible to serve as Brown PI for up to 12 months prior to the Brown appointment start date for proposal submission.
The faculty member should work closely with the administrative staff in their future department to ensure that they have an understanding of University timelines as well as the correct credentials for proposal submission.
Transfer of Data and Materials
Incoming faculty who intend to transfer data and/or tangible research materials (e.g., animal models, cell lines, specimens, plasmids, antibodies) must contact Brown’s Research Agreements and Contracting (RAC) team. A RAC staff member will work with your previous institution to determine if an agreement or written permission is required to transfer the data and materials to Brown.
Data and materials that often require an agreement include, but are not limited to, the following:
- Data provided under a data use agreement
- Data that include any of the following:
- Individually identifiable health information or protected health information (PHI)
- Personally identifiable information (PII)
- Student information derived from education records that are subject to the Family Educational Rights and Privacy Act (FERPA)
- Data that are controlled by laws or regulations other than or in addition to those listed above
- Data obtained from an individual or organization under obligations of confidentiality
- Data of which the storage, use and transfer must be controlled for other reasons (e.g., Risk Level 3 data, or data with proprietary concerns)
- Materials generated at the previous institution or materials with proprietary concerns
- Materials received from a third party under a material transfer agreement
- Materials purchased from a repository under a material transfer agreement or other terms of use such as Jackson Labs, American Type Culture Collection (ATCC), Addgene, etc.
Please contact researchcontracts@brown.edu for more information.
Research Agreements and Contracting
The Research Agreements and Contracting (RAC) team is responsible for drafting, negotiating and managing contracts and agreements in support of research at Brown.
Human Subjects Research Options for Researchers Joining Brown
If the research activities will remain active at the new faculty’s previous institution and will not engage Brown University in any way (e.g., no Brown personnel interacting with participants, no Brown access to identifiable data, Brown University is not the prime recipient of the grant), then there is no need to submit anything to Brown’s Human Research Protection Program (HRPP) or Institutional Review Board (IRB).
In this case, the study is assigned a new PI at the previous institution and Brown’s new faculty member is either no longer involved or is only conducting research activities that do not meet the definition of human subjects research and do not engage Brown.
If the research activities will be concluded at the previous institution and all study components will be fully transferred to Brown, the new faculty member needs to submit a full application for review, including study materials and any applicable appendices or attachments.
This process may begin upon receipt of an appointment letter regardless of start date. Materials may need to be revised to meet Brown's approval requirements. The current study at the previous institution should remain open until the study can be approved at Brown. Once Brown approves, the study can be closed at the previous institution. This ensures continuous ethical oversight during the transition.
If the research will continue at the previous institution but will also engage Brown, then a reliance agreement between the institutions is required to cover the research activities. This process may begin upon receipt of an appointment letter regardless of start date. The current study at the previous institution should remain open until an agreement is reached to ensure continuous ethical oversight during the transition.
Export-Controlled Equipment and Technical Data
As an new faculty member, it is important to understand that if you are transferring research to Brown that prohibits participation of foreign nationals for national security reasons or that restricts the dissemination of your research results for national security reasons, you will need to get prior approval from the Vice President for Research to bring this research to Brown.
Contact Brown’s Export Control team as early as possible if you are transferring research to Brown and any of the following applies:
- You had a Technology Control Plan (TCP) or any other type of export control compliance plan at your prior institution (if possible, please provide a copy of your prior control plan).
- You are bringing any technology, items, information or materials (“technology”) that are controlled under the International Traffic in Arms Regulations (ITAR). ITAR technology cannot be brought to Brown’s campus unless you have received written approval from the Vice President for Research.
- You are bringing any technology, items, information or materials that are controlled under the Export Administration Regulations (EAR) and that carry an export control classification other than EAR99.
- You are bringing any trainees (e.g., graduate students, postdocs) with you to Brown who are from comprehensively embargoed countries.
- Your planned research program at Brown involves international fieldwork and/or travel with specialized research equipment.
Export Controls
Learn more about export controls or reach out to Brown's export control team — a team that is part Research Integrity — for personalized assistance and guidance.
Conflict of Interest
When coming to Brown and transferring existing grants to or applying for new grants through Brown, you will be asked to submit a Conflict of Interest Reporting Form in Brown’s electronic submission system (InfoEd). InfoEd requires Brown login credentials. If you do not yet have those credentials, email coi@brown.edu to request a non-Brown reporting form.
If you were on a conflict of interest management plan at your prior institution, contact Brown’s Conflict of Interest team (part of Research Integrity) to discuss whether or not a new management plan is required. Please provide a copy of your prior management plan to the team for this review. If you continue to hold the financial interest that was being managed at your prior institution, you may also need a conflict of interest management plan at Brown.
New Investigator Onboarding Session
If you’re a new faculty member coming to Brown, you may want to schedule an onboarding session (offered via phone or Zoom) to learn about Brown’s forms, processes and policies.
To learn more about scheduling an onboarding session, please contact the Quality Assurance / Quality Improvement administrator in Research Integrity.