Transfer of NIH Grant to Another Institution
Reprinted from the NIH Grants Policy Statement
NIH Publication No. 98-146
Part II Administrative Requirements
Prior Approval Requirements
Change of Grantee Organization: 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. Such a change of grantee organization may be accomplished under most NIH grants, including construction grants, if:
- The grant to be transferred has been terminated in accordance with 45 CFR 74.61 or 92.43;
- A noncompeting continuation award that is within an approved project period has been withheld because of the grantee's actions (see "Administrative Requirements -- Enforcement Actions -- Suspension, Termination, and Withholding of Support"); or
- The original grantee has agreed to relinquish responsibility for an active project before the expiration of the approved project period. This includes any proposed change of grantee as a result of a PI on a research project transferring from one domestic organization to another domestic organization or from a foreign organization to a domestic organization. The project under the same PI may be supported at a new organization for a period up to the remainder of the previously approved project period in an amount not to exceed that previously recommended for direct costs (plus applicable F&A costs) for the remaining period.
A change of grantee organization may not take place where it will involve the transfer of a grant to or between foreign institutions or international organizations. In addition, a grant to an individual may not be transferred. However, an individual fellowship may be transferred to a new organization and this would be considered a change of grantee organization. A change in an individual fellow's department or sponsor within the same organization is not considered a change of grantee organization.
A request for a change of grantee organization must include submission of a Relinquishing Statement and a Final Invention Statement and Certification from the original grantee as well as submission of an application (PHS-398) from the proposed grantee. The application from the proposed grantee should include, at a minimum:
- A face page;
- Budget pages (current and future years);
- An updated biographical sketch;
- A statement indicating whether the overall research plans/aims have changed from the original submission, and, if so, providing updated information;
- An updated "other support" page(s), if necessary;
- A resource page;
- A checklist page;
- An approved IRB/IACUC assurance, if applicable; and
- If the change includes the transfer of equipment purchased with grant funds, the application must include a detailed list. This list, as part of a transfer application, serves as an acceptance of title by the new organization.
NIH may request additional information necessary to accomplish its review of the request.
A change of grantee organization request must be made prior to the anticipated start date at the new organization and preferably several months in advance. Failure to provide timely notification may result in disapproval of the request or a delay in processing.
A change of grantee request will normally 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 competitive review, provided the 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 office may require a competitive review or may disapprove the request and, if appropriate, terminate the award.
As stated above, the original grantee must provide a written statement relinquishing its interests and rights to the grant in accordance with instructions from the NIH awarding office. Acceptance of a Relinquishing Statement by NIH does not guarantee approval of a transfer application for the continued funding of a project.
NIH will accomplish a change of grantee organization by issuing a revised NGA to the original grantee, which will reflect the revised budget/project period end dates, deletion of any future-year support, and deobligation of remaining funds, if applicable. (A deobligation of funds will be based on the estimated grant expenditures through the relinquishment date, as determined from the Relinquishing Statement.) Concurrently, the new grantee will receive an NGA reflecting the balance reported on the Relinquishing Statement or, if the change of grantee organization occurs on the anniversary date of the project, the NGA to the new grantee will reflect the direct cost level (plus applicable F&A costs) previously committed.