Transferring a Grant or Change of Principal Investigator

This document applies to Federal grants only and addresses these situations:

• Transferring a grant to or from OSU
• Significant change in named principal investigator's effort, or change of  PI.

A PI Checklist is appended to the end of this document to assist investigators in confirming that all critical steps to the process have been completed. [For Federal contracts and non-federal agencies, including sub-agreements from other universities, check the awards terms and conditions for instructions; then work with the OSU Office of Sponsored Programs and the Office of Post-Award Administration to comply with the requirements.]

Background

When a Principal Investigator (PI) of an externally funded federal grant changes institutions, a decision is made about whether the grant stays at the current institution or is transferred to the new institution.  Because the grant award is made to the institution and not to the PI, there must be agreement with appropriate individuals as to where the grant will ultimately reside.

If the decision is to change the grantee organization to the new home of the PI, the request must be made prior to the anticipated start date at the new organization and preferably several months in advance.  Failure to provide timely notification may result in disapproval of the request or a delay in processing.

If the decision is to leave the grant award at the current organization, the sponsoring agency must be notified immediately with a request for change in responsible PI.   This correspondence may include a request to re-budget part of the award as a sub-grant to the new organization of the former PI for continued work and collaboration on the project.

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Transferring an Existing Grant

When a grant is transferred from one institution to another, there are several general steps to the process.

1. The Principal Investigator is responsible for the following actions to initiate a transfer.
2. Obtain approval from their current institution to relinquish the grant. Because awards are made to the institution and not to individual researchers or scholars, there must be agreement to relinquish the grant.  The PI, their department head and their dean must agree that the award should transfer with the PI. All Co-PIs must be notified of the grant transfer.
3. The PI should confirm the status of any cost-sharing commitment made by the original institution.  Some agencies require any cost-share commitments made at the original institution to be transferred to the new institution
4. Ascertain and follow sponsor requirements relating to transferring a grant. (Contained in this document are specific web-site references for some federal agencies.  If your sponsor is not one listed later in this document, contact the sponsor directly to determine their specific requirements.)
5. Discuss any technology developments with the Technology Transfer Office.
6. Coordinate with the sponsored programs office and the business office/Office of Post Award Administration of the current institution in completing the transfer requirements.
7. The sponsored programs office and the business office/Office of Post-Award Administration at the current institution are responsible for the following areas.
8. Determine the exact amount of unexpended or un-obligated funds.
9. Critically review any cost sharing commitments.   Have these been met?  What cost share requirement will transfer with the grant?
10. Review agreement for sub-grants.  Have they completed their portion of the project?  Notify active sub-awardees of impending move and that their current award may be terminated.  Coordinate terminations with the Contract and Business Office.
11. Review agreement for equipment purchases.   Capitalized equipment purchased on the current award may move with the PI to the new institution.  Any movement of equipment which has not been purchased with this award must be approved by the department head and have a loan agreement signed between the two institutions.  Contact the institution's Property Office.
12. Review commitments to personnel; particularly graduate students.   Will these persons still be working on this project?   If so, the new institution will need to make a sub-grant back to the original institution once the grant is transferred.
    
13. The Principal Investigator is responsible for the following actions to complete a transfer.

1. Complete paperwork from the sponsor, and secure the signature of their department head, dean (or director) and Director of Sponsored Programs on a relinquishing statement to end the award at that institution.
2. Complete the application procedures of the new institution's sponsored programs office in order to complete the grant transfer process.
3. Provide a copy of the initial proposal, initial award notice, and the most recent progress report.  Provide a copy of the scope of work if the transferring of the grant changes the scope.
4. Provide a detailed budget for the funds to be transferred, using rates appropriate for the new institution, and balance of any cost sharing to be met.  (A detailed budget includes all salaries, levels of effort, fringe benefits, travel, supplies/services, equipment, sub-awards and indirect cost.)
5. Complete and sign the institution's Proposal Transmittal Form. All units providing the commitment must approve any cost sharing obligations. The check-off sheet for Oregon State University can be found under forms at: http://www.oregonstate.edu/research/osprc/submission/index.htm#forms
6. Include verification from the department on academic appointment start date.
7. Supply a letter from the original grantee institution relinquishing the grant or copy of signed agency relinquishment form. 
8. Forward all necessary completed and signed paperwork to the funding agency.

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Specific Federal Agency Information for Transferring a Grant

National Science Foundation
NSF's policy for grant transfers	http://www.nsf.gov/pubs/policydocs/pappguide/nsf08_1/aag_index.jsp (Chapter II. Section 2.h.)
National Institutes of Health
PHS/NIH policy for grant transfers, including the Relinquishment Form	http://grants2.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part7.htm#_Toc54600127
U S Department of Agriculture
USDA/CSREES policy for change in key personnel	http://www.csrees.usda.gov/business/awards/awardterms.html (Click on General Terms and Conditions-A, the policy is under section 4. Prior Approval Requirements)
U S Department of Education
Education's policy and the Grant Transfer Agreement Bulletin #18	http://www.ed.gov/policy/fund/guid/gposbul/gposbul.html

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Significant Change of PI on an Existing Award

Since the approval of the project has, to some degree, been based on the participation or qualifications of the PI and other key personnel, the sponsor requires notification whenever there is to be a significant change in the level of participation in the awarded project by the principal investigator (PI).   The sponsor has the option to either approve or disapprove of any proposed alternate plans related to the research

Significant change in the level of participation may be defined as:

1. The PI not giving active direction of the project for a continuous period of time greater than three months, e.g. sabbatical leave, or
   
2. a 25% reduction in time devoted to the project.

The program officer at the awarding agency must be notified in a letter signed by the PI and the OSU Director of the Office of Sponsored Programs.   The letter should detail the reason for the change in key personnel and provide the replacement PI's vitae.  These requests must be made prior to implementing any changes.  OSU will make the appropriate changes to award files and financial records once written approval has been received from the sponsor.

Specific Federal Agency Information For Significant Change of PI

National Science Foundation
NSF's policy for change in key personnel	http://www.nsf.gov/pubs/policydocs/pappguide/nsf08_1/aag_index.jsp (Located under Chapter II. Section 2.c-g.)
National Institutes of Health
PHS/NIH's policy for change in key personnel	http://grants2.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part7.htm#_Toc54600127
U S Department of Agriculture
USDA/CSREES policy for change in key personnel	http://www.csrees.usda.gov/business/awards/awardterms.html (Click on General Terms and Conditions-A, the policy is under section 4. Prior Approval Requirements)
U S Department of Education
USDE's policy for change in key personnel	http://www.ed.gov/policty/fund/guid/gposbul/gpos15.html

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PI Checklist for Transfer of a Grant from Oregon State University

Reference	Checklist Date	Item
1.A.		Obtain relinquishment letter from dean to relinquish the grant.
1.A.		Obtain relinquishment letter from department head to relinquish the grant
1.A.		All Co-PI's listed on the grant must sign off on this checklist to show they are aware of the transfer of the grant.  This checklist should accompany the transfer request paperwork to the OSU Office of Sponsored Programs. Signatures of PI and all Co-PI's: Signatures                                            Date           ______________________                ___                  _________________ _              ____                 ___________________            _____                  ___________________                  __
1.C.		Ascertain and follow sponsor requirements relating to the transfer.
3.A.		Bring appropriate sponsor paperwork to the Office of Sponsored Programs for relinquishment of the grant.

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PI Checklist for Transfer of a Grant to Oregon State University

Reference	Checklist Date	Item
		Submit to the OSU Office of Sponsored Programs the following.
3.B.i.		Copy of the initial proposal.
3.B.i.		Copy of the initial award notice.
3.B.i.		Copy of the most recent progress report.
3.B.iii.		A proposal with a completed and signed OSU Proposal Transmittal Form.
3.B.ii.		New detailed budget for the funds to be transferred using OSU's fringe benefit (OPE) and F&A (indirect cost) rates.
1.B.		Details of any cost-share agreement made on the original award and how that cost-share commitment will be satisfied at OSU.
3.B.i.		Scope of work if the transferring of the grant to OSU changes the scope.  If no changes will be made to the scope of work due to the transfer of the grant then a copy of the scope of work from the original proposal can be submitted.
1.C.		Items which may or may not be needed depending on agency specifications: Revised agency cover sheet (check agency specific guidelines for transferring a grant to see if this is needed).
3.B.iv.		Verification from the department on academic appointment start date.
3.B.v.		Relinquishment letter from original institution or signed agency relinquishment form.
3.B.vi.		The PI is responsible for forwarding all necessary completed and signed paperwork to the funding agency.

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