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Change of Grantee Institution (Transfers)
Reviewed November 18, 2015
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.
A complete package of materials is needed in order for NIH to transfer a grant from one organization to another.
The old institution must submit the following documentation:
- Relinquishing Statement (PHS Form 3734) or signed letter in lieu of the form (only if transfer is taking place prior to award of competitive application). If applicable, include a list of equipment that is transferring to the new institution.
This form gives information about the date the investigator proposes to leave the old institution and proposes to start at the new institution. It provides an estimated amount of funds to be relinquished in the current grant year.
Important to Note: The Form 3734 requests "the unexpended balance on the termination date of _____calculated on the basis of the total amount awarded for the grant year." A common error is to include the total balance from all grant years (including carryover); however, this estimate should come ONLY from funds awarded in the budget period being relinquished.
Form 3734 should be completed as soon as possible and always before the PI moves. While some grantees will wait until all charges are cleared, this significantly delays the process. If there is an underestimation of expenditures, the awards will be revised.
- Final Invention Statement (PHS Form 568)
- The Final Financial Status Report (FSR) (SF 269) is required for grant closeout and is due 90 days following the termination date of the project.
Important to Note: The FSR should be submitted on time. Its acceptance triggers transfer of unexpended funds to the new institution. FSRs must be submitted electronically via the eRA Commons. See NIH Guide Notice OD-07-078 for additional details on this requirement. Also be reminded that the final Federal Cash Transactions Report (PMS 272) for the grant must match the expenditure information provided on the final FSR.
The new institution must submit a transfer application, which should be provided in PDF format (preferably 300 DPI resolution or better) to the grants manager at the applicable funding Institute or Center (I/C) at NIH. The application from the new institution should include, at a minimum:
Application face page (PHS Form 398) with "CHANGE OF GRANTEE INSTITUTION" typed in capital letters across the top of the page. (Note these form page references still reflect paper submission using the PHS398. Transitioning this process to electronic submission using the SF424 (R&R) is in process; however, no firm transition date is known. Until then, all transfers should continue to be paper submissions based on the PHS398).
- PHS398 Form Page 2—Project Performance Site Primary Location information.
- A progress report for the current year, including a statement regarding the goals of the upcoming year. This is required for anniversary transfers and is strongly encouraged for mid-year transfers.
- A statement concerning the current research plan and an indication of whether the original plan has changed. If changed, appropriate details should be provided.
- If the application involves Multiple Principal Investigators, include a revised Multiple PD/PI leadership plan indicating how the transfer will affect the governance and organization of the leadership team.
- A resources page including a description of the facilities at the new institution and the probable effect of the move on the project.
- Budget pages. If the grant is transferring in the middle of a budget period, a partial year direct cost budget, at the relinquished direct cost level is required. For grants transferring on their anniversary date, a full year budget, at the committed direct cost level is required. Future year budget pages should also be provided at the committed direct cost level. For modular grants, only narrative budget information, including total direct costs and F&A costs is required.
Important to Note: Generally, the negotiated F"A cost rate on file with the DHHS for the new institution will be applied to the direct costs for the grant, regardless if the rate is higher or lower than that of the old institution. If there are major increases in F"A costs in the current grant year, increases in the award will be contingent upon availability of funds. Future year F"A costs will be provided at the appropriate negotiated rate.
- Updated biographical sketches for new key personnel.
- Updated other support pages for all key personnel, if applicable.
- A checklist page, which should include information on the basis for computing F"A costs for the transfer period and all future years.
- Human and Animal Assurances and IRB and IACUC approval dates.
- Human subjects education certification for key personnel, if applicable.
- A list of equipment, as presented on the old institutionís Relinquishing Statement, to be transferred. Such a listing in the application represents acceptance of title to the transferred equipment.
Funding opportunity announcement PA-14-078 provides direction for the submission of electronic change of grantee applications through Grants.gov.
The signing official can submit a Relinquishing Statement electronically through eRA Commons.
The option to submit a paper change of grantee application or a paper Relinquishing Statement is still available.
Basic procedures for change of institution are also outlined in the NIH Grants Policy Statement at https://grants.nih.gov/grants/policy/nihgps_2013/. Forms can be found at https://grants.nih.gov/grants/forms.htm.