Change of Grantee

PI Leaving MCW

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  Change of Grantee (PI Leaving MCW)

If a faculty member at MCW is the Principal Investigator (PI) of an awarded NIH grant and decides to leave MCW for another institution, then there are two options for the grant:

  1. The grant can remain at MCW under a different PI. MCW will need to submit a formal request to NIH to change the PI on the award.
  2. The grant can be transferred to the PI’s new institution via the NIH Change of Grantee process, in which MCW will relinquish the award and the new institution will submit a Change of Grantee application to NIH.

Deciding whether a transfer would be appropriate will depend on the nature of the research project, whether the PI’s new institution can accommodate the research, whether there are multiple PI’s on the award, the timeline for the transfer in relation to the budget and project period of the grant, etc. Any PI planning to transfer a grant should contact his or her NIH Program Official to discuss the potential transfer, and MCW Department Chair and administrative staff as soon as possible before his or her end date at MCW to discuss the options for the grant. Per the MCW Corporate Policy on Transferring Grants, Contracts or Equipment, MCW reserves the right to request that a grant remain at MCW.

  Procedures at MCW

If the decision is made to transfer the grant out of MCW, then the following items need to be forwarded to the MCW Grants and Contracts Office (GCO) by the PI:

  1. A completed NIH Relinquishing Statement PHS 3734 form. The Relinquishing form provides MCW institutional information, the exact date of the relinquishment (normally this coincides with the PI’s last day as an MCW employee), the amount being relinquished from the current budget period, and a list of any equipment* that will transfer with the grant.
  2. A completed NIH Final Invention Statement HHS 568 form. The Final Invention Statement lists all inventions that were conceived and/or first reduced to practice during the project period that the grant was awarded to MCW. 
  3. In the email to GCO with the completed forms, provide the following information:
  • The full legal name of the PI’s new institution
  • An email for the new institution where notifications regarding the relinquishment should be sent (e.g. the email alias for the grants or sponsored research office, email for the AOR, etc.).

Once the Relinquishing Statement and Final Invention Statement have been completed, email them to aor@mcw.edu, including the information listed in item 3, above. GCO staff will then review the documents and communicate with the PI and department regarding the transfer. 

After everything is finalized and AOR signature has been obtained on the forms, the assigned GCO analyst will submit both documents to the NIH and forward a copy of the final documents to the PI’s new institution.

  Submission of Relinquishment through eRA Commons

MCW GCO current practice is to submit PDF copies of the forms directly to the NIH Grants Management Specialist of the award. NIH also allows for electronic submission of the forms in eRA Commons. The information provided in item 3 above is necessary in case NIH requests electronic submission of the Relinquishment Statement.

  Procedures at the New Institution

The PI’s new institution will need to submit a Change of Grantee application to the NIH.

  Revised NOA

After the transfer has been negotiated and awarded to the new institution, MCW receive a Notice of Award (NOA) officially relinquishing the grant.

  Transferring Equipment

If the PI intends to transfer any pieces of equipment that were paid for in whole or in part by any NIH grant, the department needs to contact the Controller’s Office. Staff will work with the department on reviewing and approving any requests to transfer equipment out of MCW. Final determinations require approval by the department and the Controller’s Office.

PI Transferring to MCW

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  Change of Grantee (PI Transferring to MCW)

When a new faculty member joins MCW and has one or more current, active NIH grants that he or she intends to transfer from his or her former institution to MCW, a Change of Grantee application must be submitted to the NIH. 

A Change of Grantee request normally will be permitted only when all of the permanent benefits attributable to the original grant can be transferred, including equipment purchased in whole or in part with grant funds. In reviewing a request to transfer a grant, NIH will consider whether there is a continued need for the grant-supported project or activity and the impact of any proposed changes in the scope of the project. A change may be made without peer review, provided the PD/PI plans no significant change in research objectives and the facilities and resources at the new organization will allow for successful performance of the project. If these conditions or other programmatic or administrative requirements are not met, the NIH awarding IC may require peer review or may disapprove the request and, if appropriate, terminate the award.

The new PI needs to work with his or her primary MCW department staff to submit the Change of Grantee application to the MCW Grants and Contracts Office (GCO) as soon as possible after the new faculty member’s start date at MCW. The PI should have already contacted the NIH regarding the transfer, and any specific NIH guidance or instructions received from the NIH Grants Management Specialist needs to be applied to the application in addition to the items listed below.

  Procedures at MCW

The Change of Grantee application is submitted to the GCO via paper forms, not in eBridge, due to the unique nature of transfer applications.  Submit the following to the GCO for every NIH Change of Grantee application:

  1. A completed Non-eBridge (Paper) MCW Registration form (PDF), with all required signatures.
  2. SFI (Disclosure of Significant Financial Interest) form (PDF) for the PI and all MCW Senior/Key Personnel.
  3. A copy of the last NIH Notice of Award (NOA) for the grant awarded to the PI’s former institution, and a copy of the NIH Relinquishing Statement from the former institution. The new PI should be able to provide these.
  4. If the project includes Human Subjects Research, the application needs to include Human Subjects Education certificates (CITI Training) for all personnel on the project participating in the IRB research, and the IRB protocol approval date.
  5. If the project includes research on Vertebrate animals, the IACUC protocol approval date is required.

 

  IRB/IACUC/Safety Approval

The transfer application can be submitted before IRB and/or IACUC approvals are granted, however NIH will most likely not award the transfer until all protocols receive approval. You can submit the transfer application materials to the GCO with compliance approvals pending.

 

  Submission Methods

The NIH currently accepts Change of Grantee applications one of two ways: Emailing the application to the NIH Grants Management Specialist using a single PDF application on PHS 398 forms, or downloading and submitting an SF424 application for the transfer using the NIH general RFA for transfers. MCW GCO current preference is to submit the application using PHS 398 forms, however the SF424 format is also acceptable. GCO will defer preference of submission method to the recommendation of the Grants Management Specialist assigned to the transfer application.

  PHS 398 Forms

If the Change of Grantee application is going to be submitted using PHS 398 forms, include the following:

A PHS 398 Face Page, with “Change of Institution” typed across the top.

Detailed PHS 398 Budget Pages that include narrative budget information (a detailed budget justification). The budget for the first period should be detailed on PHS 398 Form Page 4, and subsequent budget periods on Form Page 5.  If the grant is being transferred mid-budget period, the budget for the first period needs to match the Direct Cost amount from the Relinquishment form from the PI’s former institution. If the grant is being transferred on the anniversary date (coincides with the budget period), the budget amount needs to match the Direct Cost Recommended Level amount listed in the PI’s last NOA.

In the budget and justification, include the names of all personnel working on the project, and each individual’s calendar months effort. Explain any significant changes in level of effort for the PI and any other Key Personnel from the original application.

Updated/current Biosketches or CVs for the PI, any other Key Personnel transferring to MCW, and any newly proposed Key Personnel on the project.

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 also include a statement indicating whether the overall research plans/aims have changed from the original submission. If they have changed, provide updated information in detail.

Updated Other Support pages for the PI, any other Key Personnel transferring to MCW, and any newly proposed Key Personnel on the project.

A new Resources and Environment/Facilities page describing the research resources at MCW.This needs to include a statement concerning the current Research Plan/Specific Aims and whether the move will affect the Aims. If the Aims are changing as a result of the move, provide a detailed description of any changes. This sentence needs to be explicitly stated in the transfer application (e.g. “Transferring this project to MCW will not affect the Specific Aims as originally approved because MCW has the resources...” etc.).

A list of any equipment that is transferring to MCW.

A PHS398 Checklist page, showing the basis for computing the F&A costs per year.

After the application has been reviewed and received AOR approval, the GCO Analyst will submit it to the NIH via email if using PHS 398 forms.

  SF424 Application

If the Change of Grantee application is going to be submitted using the SF424 application package, open a new ASSIST application. After completing the application, email it to aor@mcw.edu while simultaneously submitting the hard copy registration materials listed in items 1-5 above to the GCO.

After the application has been reviewed and received AOR approval, the GCO Analyst will submit it to the NIH using ASSIST.

  Notice of Award

NIH will process a Change of Grantee application once the above information has been received. A revised NOA will be issued to the PI’s former institution that reflects the revised budget/project period end date, deletion of any future year commitments, and de-obligation of any remaining funds (the NOA will relinquish the award). Subsequently, MCW will receive a new NOA that reflects approval of the transfer to MCW, the current and future year direct cost commitments and F&A for the award along with all applicable special terms and conditions.

  Pre-Award Period

Transfer applications are not considered to be competing, so Preaward periods are not limited to 90 days.

  Unobligated Balance Transfer

Any unobligated balances from prior budget periods that were awarded to the PI’s former institution will automatically transfer to MCW after the Change of Grantee application has been awarded and final financial reports submitted and processed to NIH by the former institution.

  Transferring Equipment

If the PI intends to transfer any pieces of equipment to MCW, the department needs to contact Kate Thompson, Director of Sponsored Programs. She will work with the department on reviewing and approving any requests to transfer equipment into MCW. All equipment being transferred needs to be logged with Sponsored Programs.


Contact GCO

(414) 955-8563
aor@mcw.edu
All GCO Contacts
GCO Drop-off/ Pick-up Location:
3rd Floor MACC Fund Research Center MFRC 3080

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