Change of Grantee Institution - Outgoing Transfer
NIH prior approval is required for the transfer of the legal and administrative responsibility for a grant-supported project or activity from one legal entity to another before the expiration date of the approved project period. Outgoing transfers have three distinct requirements:
- Relinquishing Statement
- Final Invention Statement
- Final Financial Status Report
Outgoing relinquishments originate at the current awardee institution. OSP recommends that departmental administrators work closely with transferring PIs to proactively gather and communicate information to ensure a seamless transition. It is ultimately the PI's responsibility to work with his/her department to initiate the relinquishment process prior to the expiration of the approved project period, as well as prior to the anticipate start date at the new institution.
Additionally, the PI, in conjunction with his/her department must notify and coordinate transfer of said project with any VUMC central offices or departments that are affected by the relinquishment, including but not limited to the following:
- Center for Technology Transfer and Commercialization (CTTC) for patents, licenses, inventions, etc.
- Office of Contracts Management (OCM) for data use agreements, material transfer agreements, contracts, etc.
- Institutional Review Board (IRB) for projects with human subjects protocols
- Institutional Animal Care and Use Committee (IACUC) for projects with animal protocols
- Office of Clinical and Research Safety (formerly VEHS) for moving hazardous equipment or materials, vacating lab space, etc.
- VUMC Finance for invoicing, financial reporting, etc.
- Office of Faculty Affairs
The PI must also work with his/her department to collect any/all items necessary for the project's smooth transition to the new institution, including but not limited to the following:
- Contact information for the new institution's central grants office and academic/clinical department
- Comprehensive list of all grants and contracts transferring with the individual
- List of any/all equipment partially or fully purchased with grant funds that will be transferring with the project(s)
- IRB/IACUC contact information and protocol numbers at the new organization
- Material transfer agreements
- Data use agreements
- New incoming subcontracts from the new institution to VUMC
NIH may request additional information necessary to accomplish its review of the request. Acceptance of a relinquishing statement by NIH does not guarantee approval of a transfer application for the continued funding of a project.
NIH confirms a change of grantee organization by issuing a revised Notice of Award (NGA/NoA) to the original recipient reflecting the revised budget/project period end dates, deobligation of remaining funds, and deletion of any future-year support, as applicable. Please note that the deobligation of funds will be based on estimated grant expenditures through the relinquishment date, as determined by the relinquishing statement or the available balance in PMS, whichever is less.
At the same time, VUMC will receive a Notice of Award (NGA/NoA) reflecting the direct cost balance reported on the relinquishing statement plus applicable F&A costs, if funds are available. If the change of recipient organization occurs on the project’s anniversary date, the NGA to the new recipient will reflect the previously committed direct cost level plus applicable F&A costs, if funds are available. If the change of recipient organization occurs during the course of a budget period, the awarding IC’s specific policy determines whether the transfer NGA issued to VUMC will reflect a) the direct costs relinquished by the original/former recipient plus applicable F&A costs or b) the total costs relinquished by the former recipient. Depending on the closeout of the original transferring grant, this amount is subject to change and may be adjusted downward.
A transfer recipient may, at its own risk and without prior NIH approval, incur obligations and expenditures to cover costs before the begin date of a transfer award (see pre-award spending).
Please note that pre-award spending is available only if those costs are necessary to conduct the project and would not require prior approval if incurred under an awarded grant. For the purposes of pre-award costs, transfers are treated like non-competing continuation awards; therefore, the accrual of pre-award costs are not limited to 90 days prior to the begin date of the initial budget period of the transferred-to-VUMC award.
Relinquishing Statement – PHS Form 3734
Department
- Completes the form collaboratively with the PI
- Only current year DC and IDC are to be included in the relinquishing statement
- Carry forward from previous budget periods is recorded in the FFR only
- Submits the completed form to Finance for approval/signature
- Submits signed form to OSP along with Chair’s e-mail approval of relinquishment
OSP
- Reviews and approves the form
- Obtains report from Tech Transfer regarding inventions or patents associated with the grant
- Submits the Relinquishing Statement via eRA Commons
- Prints receipt for records
- May also be sent to the new institution’s contact as a courtesy
Final Financial Status Report – submitted electronically through eRA Commons by VUMC Finance. This is usually submitted within 120 days of the end date indicated on the PHS 3734. Any previous carry-forward that were not included in the PHS 3734 will be addressed at this time. Please note that all final financial reports must be internally routed to VUMC Finance 60-90 days after the end date of a project.
Final Invention Statement and Certification - This form is completed by the PI prior to departure from VUMC, and is loaded into era-Commons concurrently with the FFR. If the link is not yet available at the time of the PI’s departure, the form should be made available for upload when needed.