Transition Guidance for Outgoing Faculty and Principal Investigators

Principal Investigator (PI) transfer or terminations can involve multiple offices and actions.  To assist outgoing faculty, we’ve outlined many of the recommendations and requirements of the Office of the Vice President for Research on this page.  

Additionally, we recommend that all outgoing faculty complete the Outgoing PI Checklist

Award Relinquishment or Transfers for Outgoing Faculty 

Subaward Transfers 

Equipment Transfers 

Transfer of Data and/or Materials 

Conducting Human Subjects Research

Export Controlled Equipment/Technical Data & Licenses 

Conflict of Interest (COI)
 

Award Relinquishment or Transfers for Outgoing Faculty

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

When a faculty member who is serving as Principal Investigator of a sponsored research award transfers to a new institution, Brown must determine whether the award will be relinquished, transferred, or retained under a different PI. In all scenarios, the departing faculty member must complete certain closeout tasks relating to their awards, such as Final Report preparation and Effort Reporting before their departure.

If circumstances dictate that the PI’s sponsored research awards will be transferred to the PI’s new institution, it is important to review the sponsor’s written guidance, as the process for this type of action will vary by sponsor.  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 Statementand the proposed new recipient Transfer Application

NIH Award Steps for Outgoing Faculty

  • After the PI discusses the transfer with NIH, Brown will submit a Relinquishing Statement via the eRA Commons system. This Relinquishing Statement will include the prospective date of the transfer and the estimated award balance. To ensure that correct information is reported, the PI or Department Administrator should complete a Relinquishment Form.

  • The Award account at Brown is closed upon the PI’s departure, and after all expenditures are recorded, Brown’s Post Award office submits a Final Financial Report.  This FFR will be used by NIH to determine the transfer amount to the new organization

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 opt 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 Outgoing Faculty

  • The PI or Brown’s Authorized Institutional Official shall notify the cognizant NSF Program Officer about the PI's plan to leave the organization.

  • If the project is to continue with the original organization, the cognizant NSF Program Officer should advise the grantee to nominate a substitute PI 

  • Alternatively, if the project is to be continued at the PI’s new organization, and if NSF and both organizations agree, formal notification of the impending transfer can be initiated in Fastlane by either the PI or Brown’s Authorized Official.  This PI Transfer Request shall include:

(a) a brief summary of progress to date;

(b) a description of work yet to be accomplished;

(c) a completed on-line transfer request, including total disbursements and unpaid obligations to date (transfer amount will be automatically calculated, based on the amount entered in total disbursements). The original organization is responsible for including in the total estimated disbursements, any anticipated costs yet to be incurred against the original grant;

(d) detailed line item budget for the transfer amount and any outstanding continuing grant increments; and

(e) If funding is requested to support a postdoctoral researcher, then the request must include the requisite mentoring plan. The plan must be uploaded under “Mentoring Plan” in the Supplementary Documentation section of Fastlane. The PI must report on the mentoring activities provided to the individual(s) in annual and final project reports

  • To ensure that correct information is reported, the PI or Department Administrator should complete an NSF Award Relinquishment Form. After review, Brown’s Office of Sponsored Projects will electronically forward the request to the new organization to certify our approval of the transfer

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

  • 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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Subaward Transfers

If a departing PI is transferring awards to the PI’s new institution, and if those awards fund active subaward collaborations, then those subaward agreements should also be transferred. To achieve this, the PI and Department Administrator should request an early termination of the University’s subaward agreement by submitting a Change Order Request in Workday to change the subaward end date to correspond with the PI’s effective transfer date.

As a best practice, the Supplier Contract Change Order should be requested at least 60 days prior to the PI’s departure from the University. This timeframe allows the subrecipient to receive proper notification of the early termination, and the subrecipient will be in a better position to provide closeout documentation, final invoices, and final reporting for a smooth transfer of the award from Brown University to the PI’s new institution.

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Equipment Transfers

If a departing faculty member intends to transfer Equipment items to his or her new institution, certain approvals are required by University policy. Equipment is defined as tangible, nonexpendable, personal property having an anticipated useful life of one year or more and having a unit acquisition cost of $5,000 or greater.=

Brown University’s Movable Equipment Manual has a section dedicated to the Transfer of Property (Equipment) to Another Educational Institution, excepted below:

“When a Principal Investigator (PI) transfers to another educational institution and wishes to transfer University or federally‐owned property, s/he must furnish a written request for approval to the department chairperson or senior university officer. The PI should fully justify the request and include a list of items to be transferred obtained by physical inventory of the lab or office space. All property, regardless of value or original cost must be approved prior to transfer out of Brown. A representative at the business office of the receiving institution must certify in writing that the institution is willing to accept responsibility for the property to be transferred. The department chairperson has the initial approval authority for the transfer of property. Additional approvals must then be obtained from OSP and the Controller's Office. In addition, the external funding sponsor may need to authorize the University to transfer the property. Where title cannot be transferred, the University may be willing to loan property to enable the PI to carry on the research without interruption.”

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Transfer of Data and/or Materials

Outgoing faculty who intend to transfer data and/or tangible research materials (e.g. animal models, cell lines, specimens, plasmids, antibodies, etc.) to their new institution must contact Brown’s Research Agreements and Contracting office (RAC). RAC will review the inventory and determine if an agreement or written permission is required before the data and/or materials are transferred to a new institution. RAC will draft the appropriate agreements and send them to the new institution for review and execution. 

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

  • Data provided by a third party to Brown under a Data Use Agreement

  • Data collected at Brown or generated using Brown funds that include any of the following:

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

    • Personally identifiable information (“PII”) being shared beyond the parties named in the formal agreement or contract that governs the transfer of the data, or in the Brown IRB-approved informed consent;

    • 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 that will be shared with anyone outside of Brown, or proprietary concerns) 

  • Materials developed in the outgoing faculty’s lab while at Brown

  • Materials developed by other faculty at Brown

  • Materials developed using Brown funds

  • 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.

Note: Data and materials that require an agreement may not be transferred without a fully executed agreement. Please contact [email protected] for more information.

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Conducting Human Subjects Research

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

Studies in which the Investigator is named as the Brown PI

  • Close the study completely. This would entail submitting a Study Closure Request Form and attesting that
    • ALL identifying information for study data and/or biospecimens has been destroyed with no means of re-identification.

       

    • All participants have completed research-related interventions or interactions including long-term follow-up activities.
    • The study is permanently closed to recruitment and enrollment.
  • Transfer the study to a new PI. This would be a case where the current PI will no longer be working on the study but the research will remain active at Brown and will not engage another institution. The current PI should submit a revision request to assign a new Investigator to serve as the Brown PI along with any revised documents relevant to the change (consent, recruitment, screening, etc…).

  • Transfer the study to the new institution. This would be a case where the current PI continues the work and Brown will no longer be engaged. Current PIs would follow the same steps outlined above but Brown would wait until IRB approval has been granted at the new site to ensure there are no gaps in oversight.

  • Enact an IRB Authorization Agreement (IAA). For studies in which Brown Investigators will continue to work on the project under the auspices of a new institution while still engaging Brown in the research, the institutions must enter into a reliance agreement. The first step would be for the current PI to communicate with the new institution to ensure that their work would engage them and that the new institution would be willing to enter into a reliance agreement with Brown, either as the IRB of Record or the relying organization with Brown continuing to serve as the IRB of Record.  For further guidance and contact information, please visit Brown's Collaborative Research webpage.

For Collaborative Research in which Brown has ceded review to another institution

  • Revise the agreement. If the Brown Investigator will no longer be working on the project but Brown will remain engaged, the current PI should submit a revision request to assign an Investigator to serve as the Brown PI along with any revised documents relevant to the change (consent, recruitment, screening, etc…). Ensure the collaborators are aware of the request and take the necessary measures to revise the IAA at the IRB of Record.
  • Close the study. If Brown Investigators will no longer be working on the project and Brown will no longer be engaged, the current PI should submit a request to terminate the IAA and close the study. Per the terms of the contract, each institution must have 30-days notice prior to termination to review the closure. Ensure the collaborators are aware of the request and take the necessary measures to terminate the IAA at the IRB of Record.
  • If Brown Investigators will continue to work on the study under the auspices of the new institution and Brown will no longer be engaged, the current PI should submit a request to terminate the IAA and close the study at Brown while working with the new institution to establish a reliance agreement with the IRB of Record.

Studies in which the Investigator is named as a Brown Co-I

  • If the Brown Co-Investigator will no longer be working on the project, the PI should remove the Co-Investigator from the study.

  • If the Brown Co-Investigator will continue to work on the study under the auspices of the new institution and that work would require participant interaction or access to identifiable data, the PI will need to take steps to enact a reliance agreement with the new institution.

  • If the Co-Investigator will continue to work on the study under the auspices of the new institution and will not engage their new institution in human subjects research (participant interaction, access to identifiable data, prime awardee on the grant), this would mean that the Co-Investigator is only conducting research activities that do not meet the definition of human subjects research. A revision may need to be submitted if the change in role affects currently approved research materials, the Co-Investigator will not need to enact a reliance agreement with the new institution and there would be no need to submit to Brown’s IRB/HRPP. 

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Export Controlled Equipment/Technical Data & Licenses

If you have been on a Technology Control Plan or other Export Compliance Plan, you must contact Brown’s Export Control Team prior to leaving the institution to discuss the close out of the control plan and/or transfer of the controlled technology, information, materials, or item (“technology”) to another PI at Brown or to your new institution. 

If you have any trainees from comprehensively embargoed countries who are staying at Brown but are transferring to a new supervisor/PI, please contact the Export Control Team to discuss.

If you are leaving the University to go to a new institution outside the U.S., please note that the transfer or export of technology, hardware, materials, research tools or items (“technology”) to your new institution abroad may require an export license. Contact Brown’s Export Control Team as far in advance as possible to discuss what technology will be exported.

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Conflict of Interest (COI)

If you are on a Conflict of Interest (COI) management plan at Brown, prior to leaving the University, you should contact Brown’s COI team to discuss the close out of your COI management plan. If you are planning to transfer the grant(s) under COI management to your new institution, you should contact your new institution’s COI office. 

Conflicts of Interests that are managed in connection with Public Health Service (including NIH) or Department of Energy funded research, require annual reporting to the federal sponsors. If you are transferring grants to your new institution, this reporting requirement will also transfer to your new institution. 

After you have left Brown, if you continue to work as an Investigator on research grant(s) at Brown through an adjunct or visiting appointment (not under a subcontract to your new institution), you will continue to be subject to Brown’s COI in Research Policy. Specifically this means that you will continue to have COI reporting and COI training obligations at Brown. Important information regarding COI reporting and training requirements will be communicated to your Brown email address. Therefore, please ensure that your Brown email is linked or will be forwarded to your new institution’s email. 

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