NIH recommends that you begin the formal process of requesting the transfer of a grant at least 60 days in advance of the PI’s move to the 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 Outgoing Faculty

Relinquishing a Pending Proposal

In order to transfer a pending proposal to a new organization, Brown must first submit a Change in Recipient Organization Request.  This is facilitated through NIH’s Relinquishment process.  In order to initiate this Relinquishment, the PI or department should create a Grants Status Update (GSU) for this Funding Proposal in Huron. This GSU should indicate that we would like to relinquish the proposal, and attach a copy of the Proposal Relinquishment Form containing proper signatures.

Brown’s Authorized Official will then Relinquish the proposal via eRA Commons using the instructions found here: Starting and Working on Relinquishing Statements. The Relinquishing Statement should list the award start date as the Termination Date, and the Unexpended Balance will be left at $0, since the award is not yet made. Note that the Relinquishing Statement contains only basic proposal or award information, and does not require a narrative justification.

After receiving confirmation that the Relinquishing Statement has been submitted, the FP Specialist will Withdraw the Funding Proposal in Huron. The Reason For Withdrawal will be “Other”, with the Comment field indicating that Brown has decided to transfer this proposal to a new organization.

Relinquishing an Active Award

In order to request the transfer of an active award, the PI or Department should route an Award Modification Request (AMR) within the Huron system.  That AMR should indicate our intention to transfer the grant to a new organization and include a fully signed NIH Award Relinquishment Form.  

Brown’s Authorized Official will then confirm the estimated relinquishment amount with the OSP Post Award team before Relinquishing the proposal via eRA Commons using the instructions found here: Starting and Working on Relinquishing Statements. Note that the Relinquishing Statement contains only basic proposal or award information, and does not require a narrative justification.

After the Relinquishing Statement has been submitted, the Award Specialist will initiate an Early Termination Mod in the Huron system

The award account at Brown is closed upon the relinquishment and, after all expenditures are recorded, a Post-Award staff member submits a final financial report.  This report is used by NIH to determine the transfer amount to the new organization.

Once the transfer documentation for the proposal or award 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 opt to nominate a substitute PI or request that the grant be terminated and closed out. In those cases in which 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 Outgoing Faculty

• The PI or Brown’s authorized institutional official notifies the cognizant NSF program officer about the PI's plan to leave the organization.
• If the project is to continue with the original organization, the cognizant NSF program officer should advise the grantee to nominate a substitute PI.
• If the project is to be continued at the PI’s new organization, and if the NSF and both organizations agree, formal notification of the impending transfer can be initiated on Research.gov by either the PI or Brown’s authorized official.

What to Include in the PI Transfer Request

This PI transfer request must include the following:

• A brief summary of progress to date
• A description of work yet to be accomplished
• The completed online transfer request, including total disbursements and unpaid obligations to date (The transfer amount is automatically calculated, based on the amount entered in total disbursements. The original organization is responsible for including in the total estimated disbursements any anticipated costs yet to be incurred against the original grant.)
• A detailed line item budget for the transfer amount and any outstanding continuing grant increments
• A mentoring plan, if funding is requested to support a postdoctoral researcher (The plan must be uploaded under “Mentoring Plan” in the Supplementary Documentation section of Research.gov. The PI must report on the mentoring activities provided to the individual(s) in annual and final project reports.)

To ensure that correct information is reported, the PI or department administrator should complete an NSF Award Relinquishment Form. After review, staff in Brown’s Sponsored Projects will electronically forward the request to the new organization to certify approval of the transfer.

NSF Award Relinquishment Form [PDF]

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.

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 a departing PI is transferring awards to the PI’s new institution, and if those awards fund active subaward collaborations, those subaward agreements should also be transferred. To achieve this, the PI and department administrator should request an early termination of the University’s subaward agreement by submitting modification request in Huron to change the subaward end date to correspond with the PI’s anticipated last day at Brown University.

As a best practice, the Huron modification should be requested at least 60 days prior to the PI’s departure from the University. This timeframe allows the subrecipient to receive proper notification of the early termination, and the subrecipient will be in a better position to provide closeout documentation, final invoices and final reporting for a smooth transfer of the award from Brown University to the PI’s new institution

If the outgoing investigator on a study involving human subjects research is named as the Brown PI, you have four options: to close the study, transfer the study to a new PI or new institution or enact an Institutional Review Board Agreement (IAA).

Close the Study

Closing the study completely entails submitting a study closure request in Huron, the electronic platform for managing human subjects research studies at Brown, and attesting that all identifying information for study data and/or biospecimens has been destroyed with no means of re-identification; all participants have completed research-related interventions or interactions, including long-term follow-up activities; and the study is permanently closed to recruitment and enrollment.

Submitting a Study Closure Request [PDF]

Transfer the Study to a New PI

If the current PI will no longer be working on the study but the research will remain active at Brown and will not engage another institution, they can transfer the study to a new PI. The current PI should submit a revision request to assign a new investigator to serve as the Brown PI along with any revised documents relevant to the change (e.g., consent, recruitment, screening).

Transfer the Study to the New Institution

If the current PI will be continuing the work but Brown will no longer be engaged, they should transfer the study to their new institution. Current PIs follow the same steps as if they are transferring the study to a new PI, but Brown waits until IRB approval has been granted at the new site to ensure there are no gaps in oversight.

Enact an IRB Authorization Agreement

For studies in which Brown investigators will continue to work on the project under the auspices of a new institution while still engaging Brown in the research, the institutions must enter into a reliance agreement. First, the current PI must communicate with the new institution to ensure that their work engages them and that the new institution is willing to enter into a reliance agreement with Brown, either as the IRB of record or the relying organization with Brown continuing to serve as the IRB of Record.

For collaborative research in which Brown has ceded review to another institution, you have three options when leaving Brown: revise the agreement, close the study or establish a reliance agreement with the IRB of record.

Revise the Agreement

If the Brown investigator will no longer be working on the project but Brown will remain engaged, the current PI should submit a revision request to assign an investigator to serve as the Brown PI along with any revised documents relevant to the change (e.g., consent, recruitment, screening). Ensure the collaborators are aware of the request and take the necessary measures to revise the IAA at the IRB of record.

Close the Study

If Brown investigators will no longer be working on the project and Brown will no longer be engaged, the current PI should submit a request to terminate the IAA and close the study. Per the terms of the contract, each institution must have 30-days notice prior to termination to review the closure. Ensure the collaborators are aware of the request and take the necessary measures to terminate the IAA at the IRB of record.

Revise the Agreement

If Brown investigators will continue to work on the study under the auspices of the new institution and Brown will no longer be engaged, the current PI should submit a request to terminate the IAA and close the study at Brown while working with the new institution to establish a reliance agreement with the IRB of Record.

For studies in which the investigator is named as a Brown Co-Investigator (Co-I), the PI should remove the Brown Co-I from the study if the person will no longer be working on the project. If the Brown Co-I will continue to work on the study under the auspices of the new institution and that work would require participant interaction or access to identifiable data, the PI needs to take steps to enact a reliance agreement with the new institution.

If the Co-I is only conducting research activities that do not meet the definition of human subjects research (i.e., the Co-I will continue to work on the study under the auspices of the new institution and will not engage their new institution in human subjects research), a revision may need to be submitted. If the change in role affects currently approved research materials, the Co-I will not need to enact a reliance agreement with the new institution and there is no need to submit to Brown’s HRPP or IRB.