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Transfer of PI

By Glenn Barnes,2014-06-28 11:10
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Transfer of PI ...

    Harvard Medical School Sponsored Programs Administration

     Procedure on Transfer of Research Awards to and from other Institutions

Transfer of PI

When a Principal Investigator (PI) who receives externally funded research transfers in or out of

    Harvard Medical School, Sponsored Programs Administration (SPA) is available to act as a

    resource and help facilitate this process in the most efficient way possible. Much of the

    administrative work to assist with the transfer of research funding will be initiated by the PI who

    is changing institutions as well as the PI’s Department. SPA works to coordinate this process and

    also provides the review and institutional endorsement of the official paperwork that is needed to

    transfer the research funding.

When the PI is transferring into or out of HMS, a decision must be made as to whether the

    research will stay with the original institution or will be transferred to the new institution. A PI

    will usually prefer to transfer most or all individual awards to the new institution, and both

    institutions and sponsors generally support this desire. Some awards are less likely to be

    transferred to a new institution. These may include awards that support a number of investigators

    (such as a Center Grant) or provide more general institutional support (such as an Institutional

    NRSA award or a GCRC award from NCRR). Some sponsors will also decline to transfer

    awards that are near the end of the budget period or project period. SPA can help to interpret the

    specific terms and conditions of an award related to the transfer and can help to facilitate

    discussions necessary to complete a desired transfer.

In those cases where an award is not expected to follow the PI, the sponsoring agency should be

    notified to request a change in the PI. In come instances, the original institution may decide to

    allow the PI to establish a subcontract in order to continue work at his or her new institution.

    SPA will assist in facilitating this process including drafting and/or reviewing agreements with

    the other institution.

In cases where the award will be transferred to the PI’s new institution, a request for transfer of

    an award should be discussed with the funding agency's program officer as early in the process as

    possible so that any complications or concerns can be addressed in a timely manner. SPA is

    available to help make this a smooth transition, and therefore it is very beneficial for the

    Department or PI to notify SPA of the research funding transfer early in the process so that SPA

    can help make the transfer happen smoothly.

SPA’s procedures on the transfer of research awards are described below:

Responsible Parties:

Principal Investigators (PIs) have the ultimate responsibility for providing information about

    the move to departmental and SPA personnel in a timely manner and ensuring that the transfer of

    the award is completed in accordance with all applicable federal and sponsor regulations. The PI

    is also responsible for completing any required technical reports.

Departmental Administrators have the responsibility to conclude transactions and make any

    necessary adjustments to award accounts for departing PIs and to assist incoming PIs with

    applications.

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    Harvard Medical School Sponsored Programs Administration

     Procedure on Transfer of Research Awards to and from other Institutions

    The Sponsored Programs Administration (SPA) office shall review and institutionally endorse each sponsored program transfer. When a PI is leaving the institution, SPA shall also obtain

    signed amendments ending any outstanding subcontracts or other agreements. When a PI

    transfers into the institution, SPA will assist in reviewing and institutionally endorsing

    applications. Before these applications are awarded, SPA may also assist by approving an

    advance account so the PI can begin research.

    The Office of Sponsored Research (OSR) has the responsibility to reconcile the financial aspects of the awards and to complete the final financial statements as quickly as possible after

    termination of the award. OSR also performs the financial functions necessary to set up advance

    accounts.

Procedures

    A. To facilitate transfer of an award to another institution:

    1. Principal Investigator/Department Administrator Responsibilities:

    a. Contact SPA as soon as possible, preferably several months before anticipated

    transfer.

    b. If SPA or the Department identifies open issues related to the transferred award

    or related subcontracts at any time during the transfer process, they should work

    together to modify their action plan. When SPA or the Department reaches a

    resolution related to these open issues, they circulate this resolution to all

    relevant parties, including the PI, OSR, and the new institution as necessary.

    c. Notify the Department Chair of the anticipated transfer.

    d. Notify the Program Officer at the awarding agency of the anticipated transfer.

    e. Discuss any technology developments with the Office of Technology Licensing

    (OTL).

    f. Review the original award documentation. Pay particular attention to the

    following:

    i. Review cost sharing requirements to determine if these have been met.

    Determine what cost sharing requirements, if any, will transfer to the

    new institution.

    ii. Review the agreement for equipment, produce a list of equipment

    purchased on the current award based on PI root and equipment object

    codes, discuss with the Department Equipment Coordinator, and obtain

    signature from the Department Chairperson authorizing the transfer. The

    equipment transfer notification form is available at

    http://able.harvard.edu/forms/eq_transf_notify.pdf. Any movement of

    equipment that has not been purchased with this award must be approved

    by the Department Chairperson and should also be facilitated by the

    Department Equipment Coordinator. Refer to agency guidelines for

    specific requirements.

    g. Complete the Relinquishing form for the granting agency, submit to SPA

    i. NIH (PHS) PHS 3734: “Official Statement Relinquishing Interests and

    Rights in a Public Health Service Research Grant."

    (http://grants1.nih.gov/grants/phs3734.pdf)

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Harvard Medical School Sponsored Programs Administration

     Procedure on Transfer of Research Awards to and from other Institutions

    ii. NSF NSF 1263: “Grant Transfer Request”

    (http://www.nsf.gov/pubsys/ods/getpub.cfm?form1263)

    iii. All other funding agencies: A signed agency/corporation/foundation

    form(s) as identified by the agency.

     *This relinquishment form should contain the following:

    ? The effective date of relinquishment

    ? The estimated unexpended direct and F&A cost balances from the

    current budget period (carry-over of funds from previous budget

    periods should not be included in these amounts) *Note Try to

    error on underestimating the amount to be relinquished to allow for

    more expenses than anticipated before closeout at HMS.

    ? A statement of intent concerning the transfer of equipment.

    h. Following termination, submit the final Invention Statement and the Final

    Technical Report to the awarding agency. A progress report is typically not

    required.

    i. NIH “Final Invention Statement and Certification”

    (http://grants1.nih.gov/grants/hhs568.pdf)

    ii. NSF “Final Project Report”

    (http://www.seismo.unr.edu/ftp/pub/louie/nr/nrfinal98a-1.pdf)

    2. Sponsored Programs Administration (SPA) Responsibilities:

    a. Hold a meeting with the SPA Assistant Director (AD), Senior Sponsored

    Research Administrator (Senior SRA), and the Department Grants Manager to go

    over the PI’s portfolio and to determine necessary action steps or remaining

    financial issues. After this meeting, the Department Grants Manager should assist

    the PI with the memo requesting transfer of the award (described above). *Note

    Clinical trials will be dealt with on a case-by-case basis and may follow a

    different procedure than described in this document.

    b. Contact all subcontractors to let them know that there is an anticipated change to

    their contracted end date. Determine the current level of funding and anticipated

    expenditures and let them know that they will receive an amendment as soon as

    an end date is known.

    c. If SPA or the Department identifies open issues related to the transferred award

    or related subcontracts at any time during the transfer process, they should work

    together to modify their action plan. When SPA or the Department reaches a

    resolution related to these open issues, they circulate this resolution to all

    relevant parties, including the PI, OSR, and the new institution as necessary.

    d. Review, institutionally endorse, and submit the relinquishment statement and

    the memo as these are received from the PI. The estimate should be conservative

    to ensure that there are sufficient funds retained to meet all obligations that may

    develop. Forward a copy to OSR with a HURIS Action Form (HAF) so that they

    know to expect final invoices from the subcontractors. When reviewing the

    Relinquishing Statement, SPA should:

    i. Determine the amount of unexpended or unobligated funds. These

    estimates can be determined by using HURIS, talking to the Department

    Administrator, and discussing anticipated expenditures with

    subcontractors.

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    Harvard Medical School Sponsored Programs Administration

     Procedure on Transfer of Research Awards to and from other Institutions

e. Review commitments to personnel such as graduate students. If these

    individuals will still be working on the project, the PI and the new institution will

    need to work together to make a sub-grant back to the original institution once

    the grant is transferred.

    f. Obtain signed amendments from the subcontractors as soon as the end date is

    known to terminate HMS’s legal and financial liability for the research. Amend

    end date and request rapid final invoice. Send HAF(s) to OSR when the signed

    amendments are received to adjust the end date for each of the subcontracts.

    g. With the PI’s permission, send a copy of the Relinquishing Statement to the new

    organization.

    h. Complete HAF once the revised NGA is received from the awarding institution

    to deobligate the funds and adjust the end date for the award.

    3. Office of Sponsored Research (OSR) Responsibilities:

    a. Following termination, issue final financial report. OSR should coordinate with

    SPA to ensure that all amendments and final invoices have been received from

    the subcontractors before the final financial report is submitted.

    B. To facilitate transfer of an award from another institution to HMS:

    a. When a PI is transferring into HMS, SPA will help to ensure that equivalent of

    the above steps have taken place at the original institution and that the

    originating Sponsored Research Office has been in contact with SPA. When the

    PI is transferring into HMS, an initial meeting with the SPA Assistant Director

    (AD), Senior Sponsored Research Administrator (Senior SRA), and the

    Department Grants Manager to go over the PI’s portfolio and to determine

    necessary action steps or remaining financial issues is particularly important.

    b. SPA will work with the originating institution and sponsor to confirm the

    transfer of the project and to determine the appropriate transaction for transfer.

    This will generally involve the relinquishment of the award by the originating

    institution and transfer of the award to Harvard by the sponsor. In some cases,

    such as transfer of an award close to the end date, the sponsor may prefer the

    original institution sub-contract to Harvard rather than relinquish the award.

    Fellowship awards may require that the fellow remain a fellow of the originating

    institution when the sponsoring faculty member moves to Harvard, even if

    transferring physically. This will require clear communication with the

    fellowship office of the originating institution.

    c. If the project involves humans or animals, SPA should ensure that the PI has

    drafted the necessary protocols and submitted them to the HMS animal or

    human review board.

    d. The PI who is transferring to HMS should submit an application through HMS

    SPA in accordance with the granting agency’s policies. This cannot be

    processed until the original institution has submitted the Relinquishing

    Statement. SPA should also maintain a copy of the Relinquishing Statement in

    the award file. If the PI needs any assistance with this application, the SPA

    office is available to assist in any way possible.

    e. Once the above steps are completed, SPA will receive an award notice reflecting

    the estimated balance of the award funding to be transferred.

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    Harvard Medical School Sponsored Programs Administration

     Procedure on Transfer of Research Awards to and from other Institutions

f. If the Department submits a signed request for an Advance Account and SPA

    has also received a copy of the Relinquishing Statement from the original

    institution, SPA will work to facilitate the Advance Account so that the PI can

    continue his or her research. The PI/Project Director/Designee or the Research

    or Departmental Administrator and the Dean/Designee should sign the Advance

    Account request.

    g. After the original institution has submitted their final financial statement, the

    awarding agency may issue HMS a revised NGA to reflect a change in funding.

    This amount may be more or less than the original estimate. When applicable,

    SPA completes an HAF to inform OSR of these changes.

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