NIH Transfer Process

All NIH transfers begin at the institution the PI is leaving, and it is his/her responsibility to initiate the process. Prior to changing institutions, the PI must notify the granting agency and the exiting institution’s Office of Sponsored Projects (or equivalent).

NIH expects that requests for change in the recipient institution, as outlined in 8.1.2.7, should include mention as to whether the change in the recipient institution is related to concerns about safety and/or work environments (e.g. due to concerns of harassment, bullying, retaliation, or hostile working conditions) involving the PI. The NIH expects both the relinquishing and applicant organizations to disclose whether a Change of Recipient Organization is occurring within the context of an ongoing or recent investigation of misconduct of any kind, including but not limited to professional misconduct or research misconduct (see: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-124.html).

Outgoing transfer of an NIH award from the University of Utah requires:

1. 1. Prior written approval INTERNALLY from the University via the Relinquishing Memo (one per award) before the University/OSP can begin the formal NIH Change of Grantee/transfer process.
   
   Before submitting a Relinquishing Memo to OSP, PIs must verify that the new insitution: 1) is eligible to apply for the award; and 2) has the facilities and resources needed to carry out the work of the grant.
   
   PI's must also have notified the program officer (PO) and Grants Management Specialist (GMS) and communicated plans to transfer.
2. 2. Prior written approval EXTERNALLY from the NIH which requires a new transfer application from the new institution, as outlined below.

• A change of grantee that involves the transfer of a grant to or between a foreign institution or international organization must also be approved by the appropriate NIH Institute or Center's Advisory Council or Board.
• A grant to an individual may not be transferred. However, an individual fellowship may be transferred to a new institution. This process will be the same as for 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.
• In addition, if a mentor (i.e. K-series) or an "expert" (i.e. some R03s) is required by the conditions of the award, then that individual at the new institution must be identified and indicate his/her willingness to accept the grantee. NIH must approve this mentor. If the proposed change of institution does not meet these criteria, competitive review will be required.

Generally, it takes 90 days following the revised expiration date for the relinquishing institution to complete the close-out process. It can then take another 30-90 days for the award to be relinquished and for a new application to be submitted through the new institution. It can be another 2-3 months before a new award is made to the receiving institution. Work closely with both institutions, until the transfer is complete.

Exiting Institution STEPS

1. STEP 1: Transferring PIs should notify their Department Chair and Program Officer to discuss the possibility of transferring projects. 
   
   Transferring PIs should familiarize themselves with the NIH guidance on Change of Institution.
   
   If the PI plans to subaward back to the University of Utah, the PI should discuss this transfer with OSP before proceeding to Step 2.
2. STEP 2: If the Department Chair and Program Officer are supportive, the PI (usually with the help of the department admin) must complete a Relinquishing Memo (one per award) and submit the signed version to OSP via eAward, along with a letter of commitment from the new institution.
   
   This eAward modification will need to request the termination of all projects under the award. If the PI is starting at the new institution on August 1st, the termination date should be July 31st. 
   
   If there are existing subawards, additional modifications shall be submitted, via eAward, to request that any subawards be terminated ASAP.
3. STEP 3: If equipment costing $5k or more is to be transferred, the PI and department administrator should work with Property Accounting to complete a Retirement/Transfer Form. 
4. Step 4: After the eAward transactions are processed, Form PHS 3734 should prepared by the exiting PI/department, initialed by Grants and Contracts Accounting (GCA), and sent to OSP.  This approval will allow OSP to authorize the Relinquishing Statement.
   • Form PHS 3734, Official Statement Relinquishing Interests and Rights in a Public Health Service Grant (PDF): This form provides the effective date of relinquishment, estimated direct and indirect cost balances, and a statement of intent concerning the transfer of equipment. [Please note: If the transfer occurs before the Type 1 award is issued, a letter from the exiting institution's authorized official may be substituted for the PHS 3734.] 
     
     While some grantees will wait until all charges are cleared, this significantly delays the process. If there is an underestimation of expenditures, the awards will be revised.
     
5. Step 5: If the proposal has not yet been awarded to the University of Utah, OSP may only need to supply a letter acknowledging the relinquishing to the rights of the grant.
   
   OSP can find a letter template in Confluence.
6. STEP 6: If the award has already been issued to the University of Utah, OSP will initiate and submit the NIH Relinquishing Statement in eRA Commons in accordance with the eRA Commons Change of Institution User Guide (5 Aug 2024)
   
   OSP will need the following items:
    - New institution Name 
    - New Institution UEI
    - Requested Termination Date
    - Contact Email at the New Institution
    - Equipment Costing $5k or more transferring with the project
   
   eRA Commons will provide the unexpended remaining direct costs and unexpended remaining indirect costs.  OSP will not be able to deviate from the amounts listed. 
   
   Only current-year funds will be transferred in the relinquishing statement. The new institution will use this amount for their transfer application. Once NIH receives and accepts Utah's final financial report (FFR), any unspent previous-year funds will be transferred via a memo issued directly from NIH to the new institution. 
   
   OSP will send a copy of the submitted Relinquishing Statement to the PI and department.
7. Step 7: The following should be prepared by the exiting PI/department and submitted according to standard closeout processes
   
   
   • Standard Form 425, Federal Financial Report (PDF): This PI/department should work with GCA to submit a final financial report within 90 calendar days following the termination of the project.
   • Form HHS 568, Final Invention Statement and Certification (PDF): The PI/department should work with OSP and TLO to submit within 90 calendar days following the termination of the project.

New Institution STEPS

The NIH Change of Grantee Institution Policy requires that a transfer application be submitted through the new institution. This application will receive administrative review to determine if the transfer is appropriate and to determine the level of NIH funding. The decision to authorize the transfer of the grant will be based on the following information:

1. 1. The project has been relinquished by the University of Utah
   2. The facilities and resources at the new location allow for the successful performance of the project
   3. The PI plans no significant change in research objectives and level of expenditures from those described in the previously approved project

1. STEP 1: The PI should work with the new institution to update the eRA Commons profile affiliation. See UU instructions

2. STEP 2: The PI transferring should coordinate with the new institution to provide the following to NIH. If the PI is transferring into the University of Utah, this application will be submitted via Cayuse.

   Form PHS 398, Grant Application: The new institution must submit an electronic application using the Change of Grantee Organization opportunity (PA-24-254) found on the Parent Announcement post-award administrative action announcements.
   
   This application must contain the following information:
   1. SF 424 (R&R) Cover Component
   2. SF 424 (R&R) Project Performance Site Location(s)
   3. SF 424 (R&R) Other Project Information:
      1. Certification of IRB/IACUC approval, including assurance numbers, if applicable
      2. Facilities and Other Resources, including probable effects of the move on the project
      3. Detailed list of any equipment purchased with grant funds to be transferred to the new organization (inclusion of the list in the transfer application from the new organization indicates its acceptance of title to that equipment)
   4. SF 424 (R&R) Senior/Key Person Profile
      1. Updated biographical sketches for the PD/PI and existing senior/key personnel and biographical sketches for any proposed new senior/key personnel
      2. Updated "other support" page(s) as necessary
   5. PHS 398 Research Plan: If transferring on the anniversary date, include the progress report for the current year including a statement regarding the goals for the upcoming year. For all transfer applicationsm include a statement indicating whether the overall research plans/aims have changed from the original submission, and, if so, provide updated information.
   6. R&R Budget forms applicable for activity code (current and future years)
      1. If the award transfers in the middle of a budget period, a partial-year direct budget (at the relinquished direct cost level) is required. For grants transferring on their anniversary date or within 90 days of the end of the budget period, a full-year budget, at the committed direct cost level is required. Future year budget pages should also be provided at the committed direct cost level. For modular grants, only narrative budget information, including total direct costs and F&A costs is required;
      2. Generally the negotiated F&A cost rate on file with the DHHS for the new institution will be applied to the direct costs for the grant, regardless if the rate is higher or lower than that of the old institution. If there are major increases in F&A costs in the current grant year, increases in the award will be contingent upon the availability of funds. Future-year F&A costs will be provided at the appropriate negotiated rate.
   7. PHS 398 Cover Page Supplement
   8. PHS 398 Checklist
   9. Special justification when requesting the transfer of a budget period with less than 6 months remaining.
      
      NIH also expects that requests for change in the recipient institution, as outlined in 8.1.2.7, should include mention as to whether the change in the recipient institution is related to concerns about safety and/or work environments (e.g. due to concerns about harassment, bullying, retaliation, or hostile working conditions) involving the PD/PI. The NIH expects both the relinquishing and applicant organizations to disclose whether a Change of Recipient Organization is occurring within the context of an ongoing or recent investigation of misconduct of any kind, including but not limited to professional misconduct or research misconduct (see: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-124.html).
3. STEP 3: If transferring into the University of Utah, the PI has the option of establishing a preliminary project in anticipation of the award.