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 Grants Policy Statement

NIH Award Steps for Incoming Faculty

1. Incoming Brown faculty should ensure that their previous institutions complete and submit relinquishing statements as early as possible.  
2. 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.
3. After the transfer is approved and Brown is issued a notice of grant award (NoA) by the sponsor, a spending account is created.
4. 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

1. 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. 
2. 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
3. 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. 
4. 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
5. 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
6. 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.

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.

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