Research OSPA:Principal Investigator (PI) Transfer Process

From Office of Research Wiki
Jump to navigation Jump to search

Effective Date

September 1, 2013

Statement of the Issue

Steps to follow when a PI transfers a sponsored project to or from UTD.

Applicable Policy/Regulation

When a Principal Investigator (PI) plans to leave an organization during the course of a grant, the organization has the prerogative 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, a transfer of the grant and the assignment of remaining unobligated funds to the PI’s new organization will occur. (See Uniform Guidance (UG) 2 CFR 200.308).If the decision is to transfer the project to the PI’s new organization, the request must be made prior to the anticipated start date at the new organization, 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 departing PI’s new organization for continued work and collaboration on the project.Contracts and other agreements (federal, non-federal or federal pass-through) will have very specific instructions. Each sponsor will have different procedures and terms and conditions which govern the actions to be taken.
For additional information, see <a class="wiki external" target="_blank" data-cke-saved-href="http://grants.nih.gov/grants/policy/nihgps/HTML5/section_8/8.1_changes_in_project_and_budget.htm#Prior" href="http://grants.nih.gov/grants/policy/nihgps/HTML5/section_8/8.1_changes_in_project_and_budget.htm#Prior" rel="external">NIH Grants Policy Statement - Part II: Terms and Conditions of NIH Grant Awards – Subpart A – Section 8.1.2 Prior Approval Requirements</a> and <a class="wiki external" target="_blank" data-cke-saved-href="http://www.nsf.gov/pubs/policydocs/pappguide/nsf16001/aag_2.jsp#IIB" href="http://www.nsf.gov/pubs/policydocs/pappguide/nsf16001/aag_2.jsp#IIB" rel="external">Award and Administration Guide – Chapter II – Grant Administration – B. Changes in Project Direction or Management</a>

Process

  1. Transferring projects to the PI’s new institution will require:
    1. Copy of PI’s resignation letter
    2. School approval of resignation and transfer of active projects
    3. Review all terms and conditions of the active projects
    4. Prepare a relinquish statement :
      1. Work with PI and department to obtain final figures
      2. Include all encumbrances and expenses through PI’s last day
    5. Include subcontractor expenses, if applicable
    6. Equipment:
      1. Was any equipment purchased with grant funds?
      2. Is equipment being transferred to new institution?
      3. School approval to transfer equipment?
    7. Final Invention/patent report, if applicable
    8. Final inventory, if applicable:
      1. Will new agreements be needed to transfer inventory (samples, genetically modified mice, etc.) – Material Transfer Agreements?
    9. Are there cost share commitments?
    10. Any subcontractors on project?
      1. Notify subcontract PI of transfer
      2. Cancel remaining subcontracts
    11. Will a subcontract need to be issued back to UTD by new institution?
      1. Name of subcontract PI at UTD
      2. Statement of work
      3. Budget
      4. Internal forms – cert, export control
    12. Transfer documents sent to sponsor
    13. Transfer documents sent to new institution:
      1. Relinquishment letter
      2. List of equipment and inventory transferring, if applicable
      3. Initial proposal
      4. Initial award notice
      5. Most recent progress report
      6. Subcontract information, if applicable
      7. Subcontract to UTD information, if applicable
    14. Closeout cost center following the closeout process
  2. Substituting a PI and keeping the project at UTD will require:
    1. Copy of PI’s resignation letter
    2. School approval of resignation and substitution PI
    3. Review all terms and conditions of the active projects
    4. New internal forms:
      1. Cert
      2. Export control
      3. Budget and justification
      4. Cost share commitments, if applicable
      5. Revised research plan and impact new PI will have on project
      6. Updated biographical sketches for all senior personnel
      7. Updated current and pending support for all senior personnel
    5. Will subcontract need to be issued to original PI’s new institution?
      1. Statement of work
      2. Budget and justification
    6. Letter of Commitment
    7. Documents sent to sponsor
  3. For new faculty transferring active projects to UTD, faculty need to be affiliated with UTD in pertinent sponsor databases (e.g., eRA Commons or NSF Fastlane) and the following documents will be required:
    1. Transfer documents from old institution:
      1. Relinquish Statement
      2. List of equipment and inventory transferring, if applicable
      3. Initial proposal
      4. Initial award notice
      5. Most recent progress report
      6. Subcontract information, if applicable
    2. New internal forms:
      1. Cert
      2. Export control
      3. Budget and justification
    3. Revised research plan and impact new PI will have on project
    4. Facilities and resources page
    5. Updated biographical sketches for all senior personnel
    6. Updated current and pending support for all senior personnel
    7. Budget on required agency forms
    8. Cost share commitments, if applicable
    9. Any subcontractors on project?
      1. Subcontract PI contact information
      2. Notify subcontract PI of transfer
      3. Budget
      4. Statement of work
    10. Will any material be provided from original institution:
    11. Will new agreements be needed to transfer inventory (samples, genetically modified mice, etc.) – Material Transfer Agreements?
    12. Is any equipment being transferred from the original institution?
    13. Compliance approvals
      1. IACUC
      2. IRB and human subjects education certification
      3. Biohazard/Recombinant DNA
      4. Conflict of Interest
    14. Send transfer documents to sponsor, according to agency guidelines
    15. Once fully transferred, process according to award process

Definitions

  1. Contract - A contract is a mechanism for procurement of a product or service with specific obligations for both sponsor and recipient. Typically, a research topic and the methods for conducting the research are specified in detail by the sponsor, although some sponsors award contracts in response to unsolicited proposals.
  2. Cost sharing -
    1. The portion of the sponsored project cost not borne by the sponsor
    2. Occurs when a sponsor requires or the institution commits funds beyond the awarded amount by the sponsor
    3. UT System Administration strongly discourages cost sharing arrangements for all sponsored programs, as these arrangements involve unique accounting procedures and require funding resources from UT System Administration. Cost sharing arrangements also necessitate increased monitoring to ensure compliance.
    4. The concept of matching is synonymous with Cost Sharing.
  3. Grant - A type of financial assistance awarded to an organization for the conduct of research or other program as specified in an approved proposal. A grant is used whenever the awarding office anticipates no substantial programmatic involvement with the recipient during the performance of the activities.
  4. IACUC - According to U.S. federal law, institutions that use laboratory animals for research or instructional purposes must establish an Institutional Animal Care and Use Committee (IACUC) to oversee and evaluate all aspects of the institution's animal care and use program.
  5. Invention Report -
    1. This document lists all inventions which were conceived or first actually reduced to practice during the course of work under the grant or award, from the original effective date of support through the date of completion or termination
    2. Includes any inventions reported previously for the grant or award as part of a non-competing application
    3. Applicable to all grants and awards by the Department of Health and Human Services
  6. Inventory Report - (See UG 2 CFR 200.329 and 200.310-316)
    1. When the total equipment purchased for a project is valued at $5,000 or more, an inventory representative will prepare a report providing details about the equipment, and in some cases, requesting disposition of the equipment. This report is submitted to the sponsor.
    2. Equipment purchased on sponsored projects usually becomes the property of The University of Texas at Dallas and will be inventoried with other departmental equipment annually. If the contract specifies that equipment is to be returned, the equipment will be returned to the sponsor.
  7. Letter of Commitment – Required for any organization participating as a subcontract. The letter must state the organization’s commitment to the project, indicating the specific role it will fulfill, and state its share of the grant proceeds. The letter must be signed by an official signatory at the organization.
  8. Material Transfer Agreements - Contractual documents used for the acquisition of various biological and research materials, and occasionally data, developed by nonprofit, government and private industry. Often these materials are a necessary component of a research project and are available only from a sole source, often industry.
  9. Pass-through - A non-federal entity that provides a federal award to a subrecipient to carry out a federal program.
  10. Patent Report -
    1. Most federally sponsored projects and some other projects require a patent report, which provides a list of inventions or new technology resulting from the project.
    2. Patents and inventions are processed by the Office of Technology Commercialization.
  11. Relinquish Statement – An official statement relinquishing interests and rights to a funded grant. The original grantee is required to submit a relinquishing statement to the sponsor to proceed with the change of Institution request. Receipt of a relinquishing statement by NIH does not guarantee approval to transfer an application for the continued funding of a project.
  12. Statement of Work (SOW) - The SOW is incorporated into the subcontract and is the yardstick against which the respondent’s performance is measured. A SOW describes the work to be performed or the services to be provided. It describes tasks, directs methodologies to be used, and sets forth the period of performance. It should contain only qualitative and quantitative design and performance requirements. It must delineate the entire scope of work to be performed and specify all the tasks within that scope. It must cover the following points: What needs to be done; Who will do what; When it should be done; Where it should be done; and How the performance will be judged.
  13. Subcontract - A document written under the authority of, and consistent with the terms and conditions of an award (a grant, contract or cooperative agreement), that transfers a portion of the research or substantive effort of the prime award to another institution or organization.
  14. Unobligated Funds – The portion of funds authorized by the federal agency for expenditure by the recipient that has not been obligated by the recipient.
  15. Uniform Guidance - In effect December 26, 2014 and published by the federal Office of Management and Budget (OMB), this guidance supersedes and streamlines requirements from OMB Circulars A-21, A-87, A-110, and A-122; Circulars A-89, A-102, and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up. This guidance provides a governmentwide framework for grants management which will be complemented by additional efforts to strengthen program outcomes through innovative and effective use of grant-making models, performance metrics, and evaluation. <a class="wiki external" target="_blank" data-cke-saved-href="http://www.whitehouse.gov/omb/grants_docs" href="http://www.whitehouse.gov/omb/grants_docs" rel="external">http://www.whitehouse.gov/omb/grants_docs</a>