Transition Guidance for Incoming Faculty and Principal Investigators

The process of transitioning research as a new faculty member may require multiple steps and actions.  To help answer most of the common questions we receive regarding incoming faculty, we’ve outlined the many of the recommendations and requirements of the Office of the Vice President for Research on this page.  

Additionally, we recommend that all incoming faculty complete the Incoming PI Checklist

Incoming Award Transfers

Submitting Proposals Before Arrival at Brown University

Transfer of Data and/or Materials

Conducting Human Subjects Research

Export Controlled Equipment/Technical Data & Licenses

Conflict of Interest (COI)
 

Incoming Award Transfers

NIH | NSF | Other Federal Sponsors | Non-Federal Sponsors

Since Award Transfer policies can vary by, it is important for incoming faculty members to review agency guidance.  Below please find the guidelines associated with this process for most major sponsors:

National Institutes of Health

NIH recommends that you begin the formal process of requesting the transfer of a grant at least 60 days in advance of the PI’s move to the new organization.

The first step in this process is to contact the Program Officer (PO) to discuss the feasibility of the transfer. If no concerns are raised by your PO, then the next step is to contact the Grants Management Specialist (GMS) assigned to the award. The GMS can assist with questions about the submission of required documentation, such as the relinquishing statement and transfer application.

The process of transferring a grant or grant application to a different organization is known as a "Change of Recipient Organization” request. Informational materials are required from both the original recipient Relinquishing Statement and the proposed new recipient Transfer Application.

NIH Award Steps for Incoming Faculty

  • Incoming Brown faculty should ensure that their previous institutions complete and submit Relinquishing Statements as early as possible  

  • The PI will then submit a Transfer Application from Brown, per the Institute’s instructions. As mentioned in the section above, since different Institutes require differing information in Transfer Applications, it is recommended that the Transfer Application is based on guidance provided by the Grants Management Specialist

  • After the transfer is approved and Brown is issued a Notice of Grant Award by the sponsor, a spending account will be created

  • Unlike other types of funding, incoming transfer awards from NIH generally do not require sponsor approval for spending more than 90 days before the Budget Period Start Date.  This allows faculty to begins pending earlier on the project without waiting for the official transfer award. If the PI intends to begin spending before the transfer award has arrived, an Advance Account is recommended.

If the transferred award has subaward collaborations with other organizations, those subrecipients should be notified that their subaward agreement is ending and, if applicable, will be reissued once the grant award has been transferred to Brown University. These notifications should be sent out to the central offices at the collaborating institutions as soon as the PI confirms the plan to transfer the award. The Relinquishing Statement and Transfer Application rely on budgeting information that can only be finalized once each subrecipient has submitted their final invoice. To ensure an efficient transfer of the subaward agreement once the NIH transfer is completed, please contact the Office of Sponsored Projects, Research Subcontracting division to identify the subrecipient organizations and begin the subrecipient monitoring process.

Further information on the Change of Recipient Organization is also available in the section entitled "Prior Approval Requirements" in the NIH Grants Policy Statement.

Note that NIH Award Transfers are not guaranteed. Once the transfer documentation is received, NIH grants management and program staff will conduct an administrative review of the request to determine if the transfer is appropriate, and to determine the level of NIH funding that will be awarded to the new recipient. The decision to authorize transfer of the grant will be based upon the following criteria:

  • The project has been relinquished by the original organization.

  • The facilities and resources at the new location allow for the successful performance of the project.

  • The investigator plans no significant changes in research objectives and level of expenditures from those described in the previously approved project.

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National Science Foundation 

When a PI plans to leave an organization during the course of a grant, the organization can choose to nominate a substitute PI or request that the grant be terminated and closed out. In those cases where the PI’s original and new organizations agree, NSF will facilitate a transfer of the grant and the assignment of remaining unobligated funds to the PI’s new organization. 

NSF Award Steps for Incoming Faculty

  • After Brown receives the PI Transfer Request from the previous institution in Fastlane, we complete the request by providing a detailed budget, if requested, for the transfer amount agreed to by both organizations. 

  • A COEUS record is created by the PI’s new department at Brown, ensuring that the budget total matches the incoming award amount

  • Upon approval of the COEUS record, Brown’s Authorized Official will electronically submit the PI Transfer Request in FastLane. 

  • NSF will assign a proposal number at the time of PI Transfer Request submission. This proposal number will become the new grant number when the transfer is approved by an NSF Grants Officer

  • Upon receipt of the above material, NSF will review the request and, if approved, deduct the specified transfer amount from the original grant and re-establish it under a new grant number at the new organization. Award notification by the NSF Grants Officer will constitute NSF approval of the grant transfer. The award notification also will specify the applicable general terms and conditions that govern the grant

  • After the transfer is approved and Brown is issued a Notice of Grant Award by the sponsor, a spending account will be created

Other Important Considerations for NSF Transfers:

  • Upon transfer of the grant to the new organization, any monetary discrepancies must be resolved between the original and the new grantee. NSF will not intervene in any disputes between the two organizations regarding the transferred amount. For this reason, it’s extremely important to ensure that the amounts reflected on the PI Transfer Request match the final expenditure totals.

    • Although most collaborations under NSF awards are awarded separately and directly from NSF to each collaborating organization, if the PI’s NSF award does include a subaward collaboration, then the subrecipient should be notified that their subaward agreement is ending and, if applicable, will be reissued once the grant award has been transferred to Brown University. The subrecipient’s final invoice will be required before submitting final expenditure totals.

      • To ensure an efficient transfer of the subaward agreement once the NSF transfer is completed, please contact the Office of Sponsored Projects, Research Subcontracting division to identify the subrecipient organizations and begin the subrecipient monitoring process.

  • Equipment purchased with NSF funds for use in a specific project should remain available for use for the duration of the project. PIs who are in the midst of projects that included funding for equipment and who will continue the project at a new organization with NSF support, should arrange with their original organization to have the equipment transferred with them. Shipping costs for such equipment may be charged to the original or transferred grant as an allowable cost. Budgets should not include funds to “buy” equipment that had been previously obtained with Federal funds.

  • When the amount of time and funds remaining in a project are modest, and if both the original and new organizations are in agreement, the original organization may issue a subaward to the new organization instead of initiating a full Award Transfer. This and other possible alternatives should be discussed with the NSF Grants Officer.

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All other federal sponsors (including NASA, DOD, DOE)

For awards funded by other agencies, the transfer guidelines tend to differ by award type, so the best approach is to contact your Program Officer to determine the best way to proceed. 

Non-federal sponsors

In most cases, award agreements will indicate whether non-federal awards can be transferred to a new organization. Please contact OSP for assistance interpreting sponsor requirements.

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Submitting Proposals Before Arrival at Brown University

When an incoming faculty member intends to submit a grant proposal in advance of their start date at Brown, it is often most efficient for the proposal to be submitted by Brown, as opposed to submitting through their prior institution and transferring the future award.  Per Brown’s PI Eligibility Policy, new Tenure-track faculty become eligible to serve as Brown PI for up to 12 months prior to the Brown appointment start date for proposal submission.

The faculty member should work closely with the administrative staff in their future department to ensure that they have an understanding of University timelines as well as the correct credentials for proposal submission.

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Transfer of Data and/or Materials

Incoming faculty who intend to transfer data and/or tangible research materials (e.g. animal models, cell lines, specimens, plasmids, antibodies, etc.) must contact Brown’s Research Agreements and Contracting office (RAC). RAC will work with your previous institution to determine if an agreement or written permission is required to transfer the data and/or materials to Brown.

Data and materials that often require an agreement include, but are not limited to, the following: 

  • Data provided under a Data Use Agreement

  • Data that include any of the following:

    • Individually identifiable health information or protected health information (“PHI”); 

    • Personally identifiable information (“PII”);

    • Student information derived from education records that are subject to the Family Educational Rights and Privacy Act (“FERPA”); 

    • Data that are controlled by laws or regulations other than or in addition to those listed above; 

    • Data obtained from an individual or organization under obligations of confidentiality; 

    • Data whose storage, use, and transfer must be controlled for other reasons (e.g., Risk Level 3 data, or data with proprietary concerns) 

  • Materials generated at the previous institution or materials with proprietary concerns

  • Materials received from a third party under a Material Transfer Agreement

  • Materials purchased from a repository under a Material Transfer Agreement or other terms of use such as Jackson Labs, ATCC, Addgene, etc.

Please contact [email protected] for more information.

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Conducting Human Subjects Research

Human Research Protections Program (HRPP) Options for Researchers Joining Brown

For studies fully remaining at the previous institution 
If the research activities will remain active at the new faculty’s previous institution and will not engage Brown University in any way (participant interaction, access to identifiable data, prime awardee on the grant), there would be no need to submit anything to Brown’s IRB/HRPP. This would mean that the study is assigned a new PI at the previous institution and Brown’s new faculty member is either no longer involved or is only conducting research activities that do not meet the definition of human subjects research and does not engage Brown.

For studies fully transferring to Brown
If the research activities will be concluded at the previous institution and all study components will be fully transferred to Brown, the new faculty member would need to submit a full application for review including study materials and any applicable appendices or attachments. This process may begin upon receipt of an appointment letter regardless of start date. Materials may need to be revised to meet Brown's approval requirements. The current study at the previous institution should remain open until the study can be approved at Brown. Once Brown approves, the study can be closed at the previous institution. This ensures continuous ethical oversight during the transition.

Collaborative Research
If the research will continue at the previous institution but will also engage Brown, there will need to be a reliance agreement between the institutions to cover the research activities. This process may begin upon receipt of an appointment letter regardless of start date. The current study at the previous institution should remain open until an agreement is reached to ensure continuous ethical oversight during the transition. For further guidance and contact information, please visit Brown's Collaborative Research webpage.

New Investigator Onboarding Session

This session provides a one-on-one, in-person (or via phone / Zoom) on-boarding meeting to assist in orienting new investigators to the Brown HRPP/IRB website, forms, processes and policies.  To learn more about participating in and scheduling an onboarding session, please contact Christiana Provencal.

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Export Controlled Equipment/Technical Data & Licenses

Brown University is committed to Openness in Research, and fosters an environment of open and free academic exchange. It welcomes international students and scholars, promotes international collaborations, and engages in open exchanges within the global academic community. Brown has an Openness in Research Policy and is currently prohibiting classified or controlled research on its campus. Almost all of Brown’s research is Fundamental Research.

As an new faculty member, it is important to understand that if you are transferring research to Brown that prohibits participation of foreign nationals for national security reasons or that restricts the dissemination of your research results for national security reasons, you will need to get prior approval from the Vice President for Research to bring this research to Brown.

When should you contact Brown’s Export Control Team?

If you had a Technology Control Plan or any other type of Export Control Compliance Plan at your prior institution, you must contact Brown’s Export Control Team to discuss the need for continuing this plan at Brown. If possible, please provide a copy of your prior control plan.

If you are bringing any technology, items, information, or materials (“technology”) that are controlled under the International Traffic in Arms Regulations (ITAR), you must contact Brown’s Export Control Team as far in advance as possible. ITAR technology cannot be brought to Brown’s campus unless you have received written approval from the Vice President for Research. Contact Brown’s Export Control Team to facilitate the approval process.

If you are bringing any technology, items, information, or materials (“technology”) that are controlled under the Export Administration Regulations (EAR) and that carry an export control classification other than “EAR99”, use the following guide to help you determine when you might need to contact Brown’s Export Control Team:

  • ECCN other than EAR99: the use of EAR-controlled technology with an ECCN other than EAR99 is generally permissible. However, if the technology is used at Brown in ways that would enable a foreign national to do all of the following - operate, install, maintain, repair, refurbish and overhaul the item - then an export license for deemed export may be required. If this is anticipated, you must consult with the Export Control Team before the technology arrives at Brown.

  • ECCN 9x515 or 600 series: special attention must be paid to EAR-controlled items with a classification of ECCN of 9x515 (e.g., 9A515) or 600 series (e.g., 8B620). The “600 series” classification is designated for military items that were once subject to the ITAR. The 9x515 ECCNs describe “spacecraft” related items, and some radiation hardened microelectronic circuits that were once subject to the ITAR under USML Category XV. Bringing EAR-controlled items with these classifications requires approval from the Export Control Team because the transfer of technology for operation to many foreign nationals without a license would be a deemed export violation. 
     
  • If you are bringing any trainees (e.g., graduate students, post-docs) with you to Brown who are from comprehensively embargoed countries, please contact the Export Control Team. We will provide education on applicable sanctions regulations as well as additional restrictions that apply to nationals of comprehensively embargoed countries. 

  • If your planned research program at Brown involves international fieldwork and/or travel with specialized research equipment, please contact the Export Control Team as specific plans arise to determine if any documentation or licensing is required. 

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Conflict of Interest (COI)

When coming to Brown and transferring existing grants to or applying for new grants through Brown, you will be asked to submit a Conflict of Interest Reporting form in Brown’s electronic COI system (InfoEd). InfoEd requires Brown login credentials. If you do not yet have those, you should contact Brown’s COI Team to request a non-Brown COI form.

If you were on a COI management plan at your prior institution, contact Brown’s COI team to discuss whether or not a new COI management plan is required. Please provide a copy of your prior management plan to the COI team for this review. If you continue to hold the financial interest that was being managed at your prior institution, you may also need a COI management plan at Brown. 

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