Award TransfersAward Transfers

Office of Research Office of Research ServicesServices

ORS Brown BagORS Brown BagNovember 20, 2006November 20, 2006

OverviewOverview Transferring the legal and administrative Transferring the legal and administrative

responsibility for a grant-supported or activity from responsibility for a grant-supported or activity from one legal entity to another before the expiration one legal entity to another before the expiration requires sponsor approvalrequires sponsor approval

Normally permitted when the permanent benefits attributable Normally permitted when the permanent benefits attributable to original grant & equipment can be transferredto original grant & equipment can be transferred

Sponsor will consider need for continued support and impact Sponsor will consider need for continued support and impact of changes in the scope of projectof changes in the scope of project

Sponsor will determine if additional reviews are necessarySponsor will determine if additional reviews are necessary

NIH supported projects transfer conditionsNIH supported projects transfer conditions Grant terminated in accordance with 45 CFR 74.61 or 92.43Grant terminated in accordance with 45 CFR 74.61 or 92.43 Non-competing continuation award withheld for Non-competing continuation award withheld for

administrative reasonsadministrative reasons Original grantee has agreed to relinquish responsibility for an Original grantee has agreed to relinquish responsibility for an

active awardactive award

Sponsor ExpectationsSponsor Expectations

Notification of desire to Notification of desire to relinquish/transfer will be timely relinquish/transfer will be timely

Award will be transferred in accordance Award will be transferred in accordance with the terms and conditions identified with the terms and conditions identified in the agreement and or circulars & in the agreement and or circulars & regulationsregulations

Required forms and documentation will Required forms and documentation will contain accurate informationcontain accurate information

The Award Transfer ProcessThe Award Transfer Process

Notification/DocumentationNotification/Documentation Completion of required formsCompletion of required forms Approvals/SignaturesApprovals/Signatures Review of Expenditures/BalancesReview of Expenditures/Balances Receipt of Sponsor ApprovalReceipt of Sponsor Approval Revision of project period dates/Changes in Revision of project period dates/Changes in

awardaward Submission of Final Financial Report/InvoiceSubmission of Final Financial Report/Invoice Resolution of unexpended fundsResolution of unexpended funds

Project Transfers to New Project Transfers to New InstitutionInstitution

Federal SponsorsFederal Sponsors PI must communicate with Program Officer, Chair, PI must communicate with Program Officer, Chair,

Dean, BA and ORSDean, BA and ORS PI must prepare formal request to sponsor and have PI must prepare formal request to sponsor and have

it countersigned by ORSit countersigned by ORS Program officer, grants mgmt. specialistProgram officer, grants mgmt. specialist

Relinquishment Statement must be completed (PHS Relinquishment Statement must be completed (PHS 3734)3734)

Final ProgressFinal Progress Final Invention Statement & Certification (HHS 568)Final Invention Statement & Certification (HHS 568) Sponsor ApprovalSponsor Approval Final (FSR) Financial Status Report (SF269)/InvoiceFinal (FSR) Financial Status Report (SF269)/Invoice

Project Transfers to New Project Transfers to New InstitutionInstitution

Non-Federal SponsorsNon-Federal Sponsors PI must communicate with sponsor, Chair, PI must communicate with sponsor, Chair,

Dean, BA and ORS.Dean, BA and ORS. PI must prepare formal request to sponsor PI must prepare formal request to sponsor

& have it countersigned by ORS& have it countersigned by ORS Indicate new institution, effective date of transfer Indicate new institution, effective date of transfer

and address unexpended fundsand address unexpended funds Final progress reportFinal progress report Sponsor approvalSponsor approval Final (FSR) Financial Report/InvoiceFinal (FSR) Financial Report/Invoice

Project Remains at PennProject Remains at Penn

Federal SponsorsFederal Sponsors PI must communicate with Program Officer, PI must communicate with Program Officer,

Chair, BA and ORSChair, BA and ORS Designate a new PIDesignate a new PI PI must prepare formal request to sponsor PI must prepare formal request to sponsor

and have it countersigned by ORS and have it countersigned by ORS Program officer, grants specialistProgram officer, grants specialist

If approved, a revised notice of grant award If approved, a revised notice of grant award (NGA) will be issued to reflect changes(NGA) will be issued to reflect changes

Project Remains at PennProject Remains at Penn

Non-Federal SponsorsNon-Federal Sponsors PI must communicate with sponsor, PI must communicate with sponsor,

Chair, Dean, BA and ORSChair, Dean, BA and ORS Designate new PI to assume awardDesignate new PI to assume award PI must prepare formal request & PI must prepare formal request &

have countersigned by ORShave countersigned by ORS If approved, sponsor will provide If approved, sponsor will provide

revised award letter/noticerevised award letter/notice

Transferring Sub-awardsTransferring Sub-awards

Communication, approvals, requests, Communication, approvals, requests, closeout reports/invoices per terms of closeout reports/invoices per terms of agreementagreement

Modification for each sub-award must Modification for each sub-award must be issued by transferring institution be issued by transferring institution Change period of performance end dateChange period of performance end date Change award amount accordinglyChange award amount accordingly New sub-contract will be issued between New sub-contract will be issued between

the new parties involvedthe new parties involved

Completing the Completing the Relinquishing Statement Relinquishing Statement

(PHS3734)(PHS3734) Completed by Departmental Administrator and Completed by Departmental Administrator and

should include the following:should include the following: Institution must be The Trustees of the University of Institution must be The Trustees of the University of

PennsylvaniaPennsylvania If transferring award, include Institution or N/AIf transferring award, include Institution or N/A Effective date of termination and effective date of Effective date of termination and effective date of

resignation should be the same except under exceptional resignation should be the same except under exceptional circumstancescircumstances

Provide itemization of equipment transferring Provide itemization of equipment transferring Indicate unexpended balance based on the award for the Indicate unexpended balance based on the award for the

current budget period and the actual outlays for the current budget period and the actual outlays for the current budget period (do not include carryovers) current budget period (do not include carryovers)

Obtain ORS post award and pre-award authorized Obtain ORS post award and pre-award authorized signaturessignatures

Transfers To PennTransfers To Penn Submit required applications/forms to sponsorSubmit required applications/forms to sponsor

Federal PHS 398 or 416-1Federal PHS 398 or 416-1 Complete required university & school documentsComplete required university & school documents

Proposal must be complete upon notification of award Proposal must be complete upon notification of award transfertransfer

Review award notice/agreementReview award notice/agreement Forward documentation including carryover from Forward documentation including carryover from

prior institution to ORSprior institution to ORS Set up advance accountSet up advance account Monitor Award (PBIL/PBUD) to ensure that Monitor Award (PBIL/PBUD) to ensure that

carryover from prior institution receivedcarryover from prior institution received Monitor cash to ensure that unexpended funds from Monitor cash to ensure that unexpended funds from

prior period receivedprior period received

Other Transfer IssuesOther Transfer Issues

Transfer of award prior to official award Transfer of award prior to official award notice to the Universitynotice to the University PI must communicate with Chair, Dean, PI must communicate with Chair, Dean,

BA, & ORS BA, & ORS Prepare formal request to the sponsor and Prepare formal request to the sponsor and

have it countersigned by ORShave it countersigned by ORS Relinquish rights to proposalRelinquish rights to proposal Indicate desire to continue research at new Indicate desire to continue research at new

institution institution Provide new institution & effective date of Provide new institution & effective date of

transfer transfer

CloseoutsCloseouts Communication with ORS Communication with ORS Confirm final outlays/Freeze fundConfirm final outlays/Freeze fund Financial reports will be issued upon revision Financial reports will be issued upon revision

of notice of grant award or sponsor approvalof notice of grant award or sponsor approval Unobligated balances will be transferred in Unobligated balances will be transferred in

accordance with terms and conditions of the accordance with terms and conditions of the awardaward Federal LOC Awards-balance from prior period Federal LOC Awards-balance from prior period

transferred via FSRtransferred via FSR Other Federal- unexpended cash will be remitted Other Federal- unexpended cash will be remitted

per terms & conditionsper terms & conditions Non-Federal- unexpended cash will be remitted Non-Federal- unexpended cash will be remitted

per sponsor instructionsper sponsor instructions

CloseoutsCloseouts

Begins with notification of award transferBegins with notification of award transfer Expenditures/obligations must be reviewed Expenditures/obligations must be reviewed

Must be reasonable, allocable, consistently Must be reasonable, allocable, consistently treatedtreated

AllowableAllowable Compliance with university & sponsor policies Compliance with university & sponsor policies

Review of encumbrances/PO’sReview of encumbrances/PO’s Address equipment transfers/DispositionAddress equipment transfers/Disposition

Lessons LearnedLessons Learned Delays are normally caused by:Delays are normally caused by:

Untimely notice to sponsor & university Untimely notice to sponsor & university administratorsadministrators

Incomplete or inaccurate relinquishment Incomplete or inaccurate relinquishment statements/notification of transfersstatements/notification of transfers

Outstanding final reportsOutstanding final reports Progress, invention, and or financialProgress, invention, and or financial

Over/Underestimating unobligated balancesOver/Underestimating unobligated balances Lack of monitoring of grant expenditures upon Lack of monitoring of grant expenditures upon

notification that PI is transferring awardnotification that PI is transferring award Untimely submission of transfer application to Untimely submission of transfer application to

sponsors (new institution)sponsors (new institution) Untimely submission of FSR from prior Untimely submission of FSR from prior

institutioninstitution

Best PracticesBest Practices

Review sponsor requirementsReview sponsor requirements Begin the transfer process prior to effective Begin the transfer process prior to effective

date of transfer or as soon as PI notification is date of transfer or as soon as PI notification is receivedreceived

Send all forms and documents to ORS togetherSend all forms and documents to ORS together Review expendituresReview expenditures Freeze fund as soon as possibleFreeze fund as soon as possible Communicate with ORS accountant/contract Communicate with ORS accountant/contract

administrator regarding transfer & closeout administrator regarding transfer & closeout issuesissues

Getting Assistance on Getting Assistance on TransfersTransfers

For Financial Matters:For Financial Matters: Contact ORS accountant or Post-Award Contact ORS accountant or Post-Award

DirectorDirector

For Non-Financial Matters:For Non-Financial Matters: Contact your Contract AdministratorContact your Contract Administrator