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Brown Bag: Award Transfer
 

Brown Bag: Award Transfer

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    Brown Bag: Award Transfer Brown Bag: Award Transfer Presentation Transcript

    • Award Transfers Office of Research Services ORS Brown Bag November 20, 2006
    • 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
    • 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
    • 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
    • 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
    • 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
    • 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
    • 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
    • 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
    • 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
    • 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
    • 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
    • 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
    • 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
    • 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
    • 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
    • Getting Assistance on Transfers
      • For Financial Matters:
        • Contact ORS accountant or Post-Award Director
      • For Non-Financial Matters:
        • Contact your Contract Administrator