Award Transfers Office of Research Services ORS Brown Bag November 20, 2006

Overview Transferring the legal and administrative responsibility for a grant-supported or activity from one legal entity to another before the expiration requires sponsor approval Transferring the legal and administrative responsibility for a grant-supported or activity from one legal entity to another before the expiration requires sponsor approval Normally permitted when the permanent benefits attributable to original grant & equipment can be transferred Normally permitted when the permanent benefits attributable to original grant & equipment can be transferred Sponsor will consider need for continued support and impact of changes in the scope of project Sponsor will consider need for continued support and impact of changes in the scope of project Sponsor will determine if additional reviews are necessary Sponsor will determine if additional reviews are necessary NIH supported projects transfer conditions NIH supported projects transfer conditions Grant terminated in accordance with 45 CFR or Grant terminated in accordance with 45 CFR or Non-competing continuation award withheld for administrative reasons Non-competing continuation award withheld for administrative reasons Original grantee has agreed to relinquish responsibility for an active award Original grantee has agreed to relinquish responsibility for an active award

Sponsor Expectations Notification of desire to relinquish/transfer will be timely Notification of desire to relinquish/transfer will be timely Award will be transferred in accordance with the terms and conditions identified in the agreement and or circulars & regulations Award will be transferred in accordance with the terms and conditions identified in the agreement and or circulars & regulations Required forms and documentation will contain accurate information Required forms and documentation will contain accurate information

The Award Transfer Process Notification/Documentation Notification/Documentation Completion of required forms Completion of required forms Approvals/Signatures Approvals/Signatures Review of Expenditures/Balances Review of Expenditures/Balances Receipt of Sponsor Approval Receipt of Sponsor Approval Revision of project period dates/Changes in award Revision of project period dates/Changes in award Submission of Final Financial Report/Invoice Submission of Final Financial Report/Invoice Resolution of unexpended funds Resolution of unexpended funds

Project Transfers to New Institution Federal Sponsors Federal Sponsors PI must communicate with Program Officer, Chair, Dean, BA and ORS PI must communicate with Program Officer, Chair, Dean, BA and ORS PI must prepare formal request to sponsor and have it countersigned by ORS PI must prepare formal request to sponsor and have it countersigned by ORS Program officer, grants mgmt. specialist Program officer, grants mgmt. specialist Relinquishment Statement must be completed (PHS 3734) Relinquishment Statement must be completed (PHS 3734) Final Progress Final Progress Final Invention Statement & Certification (HHS 568) Final Invention Statement & Certification (HHS 568) Sponsor Approval Sponsor Approval Final (FSR) Financial Status Report (SF269)/Invoice Final (FSR) Financial Status Report (SF269)/Invoice

Project Transfers to New Institution Non-Federal Sponsors Non-Federal Sponsors PI must communicate with sponsor, Chair, Dean, BA and ORS. PI must communicate with sponsor, Chair, Dean, BA and ORS. PI must prepare formal request to sponsor & have it countersigned by ORS PI must prepare formal request to sponsor & have it countersigned by ORS Indicate new institution, effective date of transfer and address unexpended funds Indicate new institution, effective date of transfer and address unexpended funds Final progress report Final progress report Sponsor approval Sponsor approval Final (FSR) Financial Report/Invoice Final (FSR) Financial Report/Invoice

Project Remains at Penn Federal Sponsors Federal Sponsors PI must communicate with Program Officer, Chair, BA and ORS PI must communicate with Program Officer, Chair, BA and ORS Designate a new PI Designate a new PI PI must prepare formal request to sponsor and have it countersigned by ORS PI must prepare formal request to sponsor and have it countersigned by ORS Program officer, grants specialist Program officer, grants specialist If approved, a revised notice of grant award (NGA) will be issued to reflect changes If approved, a revised notice of grant award (NGA) will be issued to reflect changes

Project Remains at Penn Non-Federal Sponsors Non-Federal Sponsors PI must communicate with sponsor, Chair, Dean, BA and ORS PI must communicate with sponsor, Chair, Dean, BA and ORS Designate new PI to assume award Designate new PI to assume award PI must prepare formal request & have countersigned by ORS PI must prepare formal request & have countersigned by ORS If approved, sponsor will provide revised award letter/notice If approved, sponsor will provide revised award letter/notice

Transferring Sub-awards Communication, approvals, requests, closeout reports/invoices per terms of agreement Communication, approvals, requests, closeout reports/invoices per terms of agreement Modification for each sub-award must be issued by transferring institution Modification for each sub-award must be issued by transferring institution Change period of performance end date Change period of performance end date Change award amount accordingly Change award amount accordingly New sub-contract will be issued between the new parties involved New sub-contract will be issued between the new parties involved

Completing the Relinquishing Statement (PHS3734) Completed by Departmental Administrator and should include the following: Completed by Departmental Administrator and should include the following: Institution must be The Trustees of the University of Pennsylvania Institution must be The Trustees of the University of Pennsylvania If transferring award, include Institution or N/A If transferring award, include Institution or N/A Effective date of termination and effective date of resignation should be the same except under exceptional circumstances Effective date of termination and effective date of resignation should be the same except under exceptional circumstances Provide itemization of equipment transferring Provide itemization of equipment transferring Indicate unexpended balance based on the award for the current budget period and the actual outlays for the current budget period (do not include carryovers) Indicate unexpended balance based on the award for the current budget period and the actual outlays for the current budget period (do not include carryovers) Obtain ORS post award and pre-award authorized signatures Obtain ORS post award and pre-award authorized signatures

Transfers To Penn Submit required applications/forms to sponsor Submit required applications/forms to sponsor Federal PHS 398 or Federal PHS 398 or Complete required university & school documents Complete required university & school documents Proposal must be complete upon notification of award transfer Proposal must be complete upon notification of award transfer Review award notice/agreement Review award notice/agreement Forward documentation including carryover from prior institution to ORS Forward documentation including carryover from prior institution to ORS Set up advance account Set up advance account Monitor Award (PBIL/PBUD) to ensure that carryover from prior institution received Monitor Award (PBIL/PBUD) to ensure that carryover from prior institution received Monitor cash to ensure that unexpended funds from prior period received Monitor cash to ensure that unexpended funds from prior period received

Other Transfer Issues Transfer of award prior to official award notice to the University Transfer of award prior to official award notice to the University PI must communicate with Chair, Dean, BA, & ORS PI must communicate with Chair, Dean, BA, & ORS Prepare formal request to the sponsor and have it countersigned by ORS Prepare formal request to the sponsor and have it countersigned by ORS Relinquish rights to proposal Relinquish rights to proposal Indicate desire to continue research at new institution Indicate desire to continue research at new institution Provide new institution & effective date of transfer Provide new institution & effective date of transfer

Closeouts Communication with ORS Communication with ORS Confirm final outlays/Freeze fund Confirm final outlays/Freeze fund Financial reports will be issued upon revision of notice of grant award or sponsor approval Financial reports will be issued upon revision of notice of grant award or sponsor approval Unobligated balances will be transferred in accordance with terms and conditions of the award Unobligated balances will be transferred in accordance with terms and conditions of the award Federal LOC Awards-balance from prior period transferred via FSR Federal LOC Awards-balance from prior period transferred via FSR Other Federal- unexpended cash will be remitted per terms & conditions Other Federal- unexpended cash will be remitted per terms & conditions Non-Federal- unexpended cash will be remitted per sponsor instructions Non-Federal- unexpended cash will be remitted per sponsor instructions

Closeouts Begins with notification of award transfer Begins with notification of award transfer Expenditures/obligations must be reviewed Expenditures/obligations must be reviewed Must be reasonable, allocable, consistently treated Must be reasonable, allocable, consistently treated Allowable Allowable Compliance with university & sponsor policies Compliance with university & sponsor policies Review of encumbrances/PO’s Review of encumbrances/PO’s Address equipment transfers/Disposition Address equipment transfers/Disposition

Lessons Learned Delays are normally caused by: Delays are normally caused by: Untimely notice to sponsor & university administrators Untimely notice to sponsor & university administrators Incomplete or inaccurate relinquishment statements/notification of transfers Incomplete or inaccurate relinquishment statements/notification of transfers Outstanding final reports Outstanding final reports Progress, invention, and or financial Progress, invention, and or financial Over/Underestimating unobligated balances Over/Underestimating unobligated balances Lack of monitoring of grant expenditures upon notification that PI is transferring award Lack of monitoring of grant expenditures upon notification that PI is transferring award Untimely submission of transfer application to sponsors (new institution) Untimely submission of transfer application to sponsors (new institution) Untimely submission of FSR from prior institution Untimely submission of FSR from prior institution

Best Practices Review sponsor requirements Review sponsor requirements Begin the transfer process prior to effective date of transfer or as soon as PI notification is received Begin the transfer process prior to effective date of transfer or as soon as PI notification is received Send all forms and documents to ORS together Send all forms and documents to ORS together Review expenditures Review expenditures Freeze fund as soon as possible Freeze fund as soon as possible Communicate with ORS accountant/contract administrator regarding transfer & closeout issues Communicate with ORS accountant/contract administrator regarding transfer & closeout issues

Getting Assistance on Transfers For Financial Matters: For Financial Matters: Contact ORS accountant or Post-Award Director Contact ORS accountant or Post-Award Director For Non-Financial Matters: For Non-Financial Matters: Contact your Contract Administrator Contact your Contract Administrator