Division of Research
Transition Guidance for Outgoing Faculty PIs
Tools for Outgoing Faculty PIs
The Division recommends that all outgoing faculty members complete this checklist, a Google form that provides guidelines and recommendations for PIs who are leaving 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.
Award Relinquishment or Transfers for Outgoing Faculty
When a faculty member who is serving as PI of a sponsored research award transfers to a new institution, Brown must determine whether the award will be relinquished, transferred or retained under a different PI. In all scenarios, the departing faculty member must complete certain closeout tasks relating to their awards, such as final report preparation and effort reporting before their departure.
If circumstances dictate that the PI’s sponsored research awards will be transferred to the PI’s new institution, it is important to review the sponsor’s written guidance, as the process for this type of action will vary by sponsor. The Division of Research provides award transfer process guidelines below for the National Institutes of Health (NIH) and National Science Foundation (NSF).
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 Award Steps for Outgoing Faculty
- After the PI discusses the transfer with NIH, Brown submits a relinquishing statement via the eRA Commons system. This statement will include the prospective date of the transfer and the estimated award balance. To ensure that correct information is reported, the PI or department administrator should complete an NIH Relinquishment Form.
- The award account at Brown is closed upon the PI’s departure 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.
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 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 a change order request in Workday to change the subaward end date to correspond with the PI’s anticipated last day at Brown University.
As a best practice, the supplier contract change order 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.
Equipment Transfers
If a departing faculty member intends to transfer equipment items to their new institution, certain approvals are required by University policy. Equipment is defined as tangible, nonexpendable, personal property having an anticipated useful life of one year or more and having a unit acquisition cost of $5,000 or greater.
When a PI transfers to another educational institution and wishes to transfer University or federally owned property, the PI must furnish a written request for approval to the department chairperson or senior University officer. The PI should fully justify the request and include a list of items to be transferred, obtained by physical inventory of the lab or office space. All property, regardless of value or original cost must be approved prior to transfer out of Brown.
A representative at the business office of the receiving institution must certify in writing that the institution is willing to accept responsibility for the property to be transferred. The department chairperson has the initial approval authority for the transfer of property. Additional approvals must then be obtained from Sponsored Projects and the Controller's Office. In addition, the external funding sponsor may need to authorize the University to transfer the property. Where title cannot be transferred, the University may be willing to loan property to enable the PI to carry on the research without interruption.
This guidance can be found in Brown’s Movable Equipment Manual, in the section “Transferring Property to Another Educational Institution.”
Transfer of Data and Materials
Outgoing faculty who intend to transfer data and/or tangible research materials (e.g., animal models, cell lines, specimens, plasmids, antibodies) to their new institution must contact Brown’s Research Agreements and Contracting (RAC) team. A RAC staff member will review the inventory and determine if an agreement or written permission is required before the data and/or materials are transferred to a new institution. RAC staff will draft the appropriate agreements and send them to the new institution for review and execution.
Data and materials that often require an agreement include, but are not limited to, the following:
- Data provided under a data use agreement
- Data collected at Brown or generated using Brown funds 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 developed in the outgoing faculty’s lab while at Brown
- Materials developed by other faculty at Brown
- Materials developed using Brown funds
- 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.
Data and materials that require an agreement may not be transferred without a fully executed agreement. 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 Leaving Brown
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.
Export-Controlled Equipment and Technical Data
Contact Brown’s Export Control team as early as possible in any of the following situations:
- If you have been on a Technology Control Plan (TCP) or other export compliance plan (Contact Export Control prior to leaving the institution to discuss the closeout of the control plan or transfer of the controlled technology, information, materials or item to another PI at Brown or to your new institution.)
- If you have any trainees from comprehensively embargoed countries who are staying at Brown but are transferring to a new supervisor/PI
- If you are leaving the University to go to a new institution outside the U.S. (The transfer or export of technology, hardware, materials, research tools or items to your new institution abroad may require an export license.)
Conflict of Interest
If you are on a conflict of interest management plan at Brown, prior to leaving the University, you should contact Brown’s Research Integrity team to discuss the plan’s closeout. If you are planning to transfer a grant under a management plan to your new institution, you should contact your new institution’s conflict of interest office.
Conflicts of interest that are managed in connection with research funded through the U.S. Public Health Service (including the NIH) or the U.S. Department of Energy require annual reporting to the federal sponsors. If you are transferring grants to your new institution, this reporting requirement will also transfer to your new institution.
After you have left Brown, if you continue to work as an investigator on a research grant at Brown through an adjunct or visiting appointment (not under a subcontract to your new institution), you will continue to be subject to Brown’s Conflict of Interest in Research Policy. Specifically this means that you will continue to have reporting and training obligations at Brown. Important information regarding conflict of interest reporting and training requirements will be communicated to your Brown email address. Please ensure that your Brown email is linked or will be forwarded to your new institution’s email.