Institutional Transfer of Grants & Contracts
Best Practice
Departments should establish internal policy on handling institution transfer of grants/contracts. Communication amongst the interested parties is very important.
Careful consideration should be made before agreeing to transfer grants that require follow-up visit for study subjects, are nearing the project end date, are on the brink of discovery, or where the majority of the work still needs to take place at the University of Michigan.
There may be instances when it is necessary to transfer, or relinquish, a Grant or Contract to a new institution. For example, a Principal Investigator transferring to a new institution may wish to transfer their projects. The decision to relinquish a grant/contract must be discussed with and agreed to by the Department Chair, and the Chief Department Administrator. All parties should keep in mind that awards are issued to the institution, not the investigator. When considering request to relinquish a grant or contract, the Department/Unit should protect the interests of the institution. Transfers do not apply to Research Subaward Agreements where the University of Michigan is the subrecipient, subaward agreements are amended to terminate the agreement with the University of Michigan and the Pass-through Entity (PTE) establishes a subaward agreement with the new subrecipient.
The Department/Unit should consider the following transfer principles:
Original grantee institution must be willing to transfer (UM has the right to retain the grant/contract under certain circumstances)
Sponsor has the right to disagree
Facilities and resources at new institution must be adequate
No significant changes in the research should be required due to the move
Procedure for initiating an institutional transfer:
Review the sponsor requirements to determine if institutional transfer of the grant is allowed.
If institutional transfer of grant is allowable, once approved by the PI and department Chair, the following steps should be taken:
Work with PI, department, and HR to determine the future plans for the research staff and students. This should happen a minimum of three months prior to the transfer date to allow time for Reduction-In-Force of staff, if necessary.
Identify expenses through the termination with the PI and project team and add Unit Defined Commitments as necessary. Re-iterate the importance of including all expenses, even if they are only estimates. Remember to financially account for any potential vacation payout amounts for staff ending employment.
Inform Tier 2 and any other individuals responsible for managing procurement activities of the pending grant / contract transfer and any potential impact to procurement for the remainder of the project.
If applicable, notify subcontractors and request estimates for charges through the project end date. Notify them not to bill past the anticipated end date and get their confirmation in writing. The confirmation can serve as supporting documentation to dispute any non-applicable late charges. Notify the Office of Contract Administration that a transfer is planned and initiate closing any open subcontracts.
Inform all vendors that the project is transferring, and provide them with the anticipated end-date.
Fill out any necessary forms provided by the sponsor to request the institutional transfer and submit an Award Change Request for a Transfer to a New Institution.
Once the transfer is approved, ORSP will issue an Award Modification revising the project end date. The modification is processed by Sponsored Programs to update the project end date on the Chartfield Panels. The SAPOC receives the Final FSR and coordinates with the PI and reporting account to ensure all project expenses are included on the report.
Additional considerations:
Due to variation in work roles within departments, items listed below may not be the responsibility of the post-award administrator. However each items require lead time, so it is important for units to plan accordingly.
Personnel: be prepared to arrange for Reduction-in -Force when needed. Refer to the SPG 201.72 Reduction-in-Force for policies and notification guidelines.
Units may wish to consider a replacement mentor and project reassignment for Graduate Student Research Assistants.
Equipment: Consult with the Property Control Office. SPG 520.01 Acquisition, Use and Disposition of Property (Exclusive of Real Property) contains additional information.
Data Agreements: Consult with the Office of Tech Transfer and/or ORSP to find out any transferability issues and other administrative requirements for this process.
Decommission the Laboratory: Labs must be free of all chemical, radioactive, and biological materials. Visit the Environment, Health & Safety Lab Decommissioning website for additional information and a Laboratory Decommissioning Checklist.
Effort Certification: As-Needed Effort Certifications must be completed before PI and/or staff leave.
Record Retention: Before the PI and his/her staff leave, make sure to obtain records that may be required in the event of a financial audit.
Important
Dean/Director (Medical School) approval is required on ACR's to initiate a Transfer to New Institution. Requests route for Dean approval automatically in the system please make sure all appropriate supporting documents are uploaded for review and approval prior to routing the request.
Resources
Medical School Transferring Grants Presentation
NIH 8.1.2.7 Change of Recipient Organization 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 completion date of the approved project period (competitive segment).