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.
With Change of Recipient Organization requests, timing is critical. NIAMS expects to be notified at least three months prior to the date of transfer. Any notification after this time could cause delays that could adversely impact research. Please also consider that transfer applications that come in close to the end of the Fiscal Year may be deferred for processing until after fiscal year close.
NIAMS usually will not consider or approve the transfer of a grant in a no-cost extension, except under an extraordinary circumstance. If a recipient believes they have an extraordinary circumstance NIAMS should consider, they must contact both assigned grants management specialist and program officer prior to requesting a transfer of a grant in a no-cost extension.
For prior approval requests, a complete package of materials is needed in order for NIH to transfer a grant from one organization to another.
Current Institution Requirements
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. The relinquishment statement can be submitted electronically through eRA Commons.
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).
- A final Federal Financial Report (FFR) is required for grant closeout and is due 120 days after the end of the competitive segment.
Important to Note: The FFR should be submitted on time. Its acceptance triggers transfer of unexpended funds to the new institution. FFRs must be submitted electronically via the Payment Management System. See NIH Guide Notice OD-21-060 for additional details on this requirement.
New Institution Requirements - Submitting an Electronic Application
The new institution may submit an electronic Type 7 application using the Change of Grantee Organization opportunity found on the Parent Funding Opportunity Announcement page under Post-award Administrative Action Announcements. This is the preferred submission method; however if the new institution is unable to submit electronically, they may use the PHS 398 forms sent via email.
The electronic application submitted in response to the Change of Grantee Organization (Type 7 Parent Clinical Trial Optional) Parent Announcement from the Proposed/New recipient institution should include, at a minimum, the following:
- SF 424 (R&R) Cover Component
- SF 424 (R&R) Project Performance Site Location(s)
- SF 424 (R&R) Other Project Information:
- Certification of IRB/IACUC approval, including OHRP and OLAW assurance numbers, if applicable.
- Facilities and Other Resources, including probable effect of the move on the project.
- Detailed list of any equipment purchased with grant funds to be transferred to the new organization (inclusion of the list in the transfer application from the new organization indicates its acceptance of title to that equipment).
- SF 424 (R&R) Senior/Key Person Profile:
- Updated biographical sketches for the PD/PI and existing senior/key personnel and biographical sketches for any proposed new senior/key personnel
- Updated "other support" page(s) as necessary.
- PHS 398 Research Plan: If transferring on the anniversary date, include the progress report for the current year including a statement regarding the goals for the upcoming year. For all transfer applications include also a statement indicating whether the overall research plans/aims have changed from the original submission, and, if so, provide updated information.
- R&R Budget forms applicable for activity code (current and future years).
- 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 or within 90 days of the end of the budget period, 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
- PHS 398 Cover Page Supplement
- PHS 398 Checklist
NIH also expects that requests for change in recipient institution, as outlined in 184.108.40.206, should include mention as to whether the change in recipient institution is related to concerns about safety and/or work environments (e.g. due to concerns about harassment, bullying, retaliation, or hostile working conditions) involving the PD/PI. The NIH expects both the relinquishing and applicant organizations to disclose whether a Change of Recipient Organization is occurring within the context of an ongoing or recent investigation of misconduct of any kind, including but not limited to professional misconduct or research misconduct (see: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-124.html).
Basic procedures for change of institution are also outlined in the NIH Grants Policy Statement
Find all of the forms you need for the process.