Brown Bag: Award Transfer

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  • 1. Award Transfers Office of Research Services ORS Brown Bag November 20, 2006
  • 2. Overview
    • Transferring the legal and administrative responsibility for a grant-supported or activity from one legal entity to another before the expiration requires sponsor approval
      • Normally permitted when the permanent benefits attributable to original grant & equipment can be transferred
      • Sponsor will consider need for continued support and impact of changes in the scope of project
      • Sponsor will determine if additional reviews are necessary
    • NIH supported projects transfer conditions
      • Grant terminated in accordance with 45 CFR 74.61 or 92.43
      • Non-competing continuation award withheld for administrative reasons
      • Original grantee has agreed to relinquish responsibility for an active award
  • 3. Sponsor Expectations
      • Notification of desire to relinquish/transfer will be timely
      • Award will be transferred in accordance with the terms and conditions identified in the agreement and or circulars & regulations
      • Required forms and documentation will contain accurate information
  • 4. The Award Transfer Process
    • Notification/Documentation
    • Completion of required forms
    • Approvals/Signatures
    • Review of Expenditures/Balances
    • Receipt of Sponsor Approval
    • Revision of project period dates/Changes in award
    • Submission of Final Financial Report/Invoice
    • Resolution of unexpended funds
  • 5. Project Transfers to New Institution
    • Federal Sponsors
        • PI must communicate with Program Officer, Chair, Dean, BA and ORS
        • PI must prepare formal request to sponsor and have it countersigned by ORS
          • Program officer, grants mgmt. specialist
        • Relinquishment Statement must be completed (PHS 3734)
        • Final Progress
        • Final Invention Statement & Certification (HHS 568)
        • Sponsor Approval
        • Final (FSR) Financial Status Report (SF269)/Invoice
  • 6. Project Transfers to New Institution
    • Non-Federal Sponsors
        • PI must communicate with sponsor, Chair, Dean, BA and ORS.
        • PI must prepare formal request to sponsor & have it countersigned by ORS
          • Indicate new institution, effective date of transfer and address unexpended funds
        • Final progress report
        • Sponsor approval
        • Final (FSR) Financial Report/Invoice
  • 7. Project Remains at Penn
    • Federal Sponsors
        • PI must communicate with Program Officer, Chair, BA and ORS
        • Designate a new PI
        • PI must prepare formal request to sponsor and have it countersigned by ORS
          • Program officer, grants specialist
        • If approved, a revised notice of grant award (NGA) will be issued to reflect changes
  • 8. Project Remains at Penn
    • Non-Federal Sponsors
        • PI must communicate with sponsor, Chair, Dean, BA and ORS
        • Designate new PI to assume award
        • PI must prepare formal request & have countersigned by ORS
        • If approved, sponsor will provide revised award letter/notice
  • 9. Transferring Sub-awards
    • Communication, approvals, requests, closeout reports/invoices per terms of agreement
    • Modification for each sub-award must be issued by transferring institution
      • Change period of performance end date
      • Change award amount accordingly
      • New sub-contract will be issued between the new parties involved
  • 10. Completing the Relinquishing Statement (PHS3734)
    • Completed by Departmental Administrator and should include the following:
      • Institution must be The Trustees of the University of Pennsylvania
      • If transferring award, include Institution or N/A
      • Effective date of termination and effective date of resignation should be the same except under exceptional circumstances
      • Provide itemization of equipment transferring
      • Indicate unexpended balance based on the award for the current budget period and the actual outlays for the current budget period (do not include carryovers)
      • Obtain ORS post award and pre-award authorized signatures
  • 11. Transfers To Penn
    • Submit required applications/forms to sponsor
      • Federal PHS 398 or 416-1
    • Complete required university & school documents
      • Proposal must be complete upon notification of award transfer
    • Review award notice/agreement
    • Forward documentation including carryover from prior institution to ORS
    • Set up advance account
    • Monitor Award (PBIL/PBUD) to ensure that carryover from prior institution received
    • Monitor cash to ensure that unexpended funds from prior period received
  • 12. Other Transfer Issues
    • Transfer of award prior to official award notice to the University
      • PI must communicate with Chair, Dean, BA, & ORS
      • Prepare formal request to the sponsor and have it countersigned by ORS
        • Relinquish rights to proposal
        • Indicate desire to continue research at new institution
        • Provide new institution & effective date of transfer
  • 13. Closeouts
    • Communication with ORS
    • Confirm final outlays/Freeze fund
    • Financial reports will be issued upon revision of notice of grant award or sponsor approval
    • Unobligated balances will be transferred in accordance with terms and conditions of the award
      • Federal LOC Awards-balance from prior period transferred via FSR
      • Other Federal- unexpended cash will be remitted per terms & conditions
      • Non-Federal- unexpended cash will be remitted per sponsor instructions
  • 14. Closeouts
    • Begins with notification of award transfer
    • Expenditures/obligations must be reviewed
      • Must be reasonable, allocable, consistently treated
      • Allowable
      • Compliance with university & sponsor policies
    • Review of encumbrances/PO’s
    • Address equipment transfers/Disposition
  • 15. Lessons Learned
    • Delays are normally caused by:
      • Untimely notice to sponsor & university administrators
      • Incomplete or inaccurate relinquishment statements/notification of transfers
      • Outstanding final reports
        • Progress, invention, and or financial
      • Over/Underestimating unobligated balances
      • Lack of monitoring of grant expenditures upon notification that PI is transferring award
      • Untimely submission of transfer application to sponsors (new institution)
      • Untimely submission of FSR from prior institution
  • 16. Best Practices
    • Review sponsor requirements
    • Begin the transfer process prior to effective date of transfer or as soon as PI notification is received
    • Send all forms and documents to ORS together
    • Review expenditures
    • Freeze fund as soon as possible
    • Communicate with ORS accountant/contract administrator regarding transfer & closeout issues
  • 17. Getting Assistance on Transfers
    • For Financial Matters:
      • Contact ORS accountant or Post-Award Director
    • For Non-Financial Matters:
      • Contact your Contract Administrator