Closeout and Principal Investigator Transfer

The RPPR report is due within 90 days of the end of the award for most federal grants.  The report length and content vary depending on the sponsor.  Such reports range from a summary and list of publications to a complete, exhaustive compilation of the project results. The PI is responsible for the submission of all technical reports required under the terms of an award in the form required by the sponsor.  

NIH requires submission of the final RPPR report via eCommons.  The PI logs into eRA Commons and clicks the status tab at the top of the screen.  The PI selects the “Requires Closeout”.  Once the PI has completed the final reporting electronically, he/she should route to OSP to provide the institutional approval of the final RPPR report.

The Office of Sponsored Programs is responsible for the completion and submission of the final Federal Financial Report. The report is prepared and submitted to the sponsor within 90 days of the award’s expiration date, or as required by the award's terms and conditions.  In a few instances, it may be difficult for the OSP-Post Award Unit to meet this deadline due to the processing of payroll, removal of unallowable charges, unpaid obligations, and pending recipient of the sub-awardee’s final invoices that occurred within the period of performance. 

Please note that any purchases at the end of the award period generate intense scrutiny and are red flags to an auditor.  Federal sponsors require that expenditures are incurred, received, and provide necessary benefits between the start and end date of the applicable period of performance.  Benefit is defined as having a reasonable amount of usage (at least six months) during the period of performance.

We are responsible for reconciling the report prior to submitting it to NIH.  The Final FFR must indicate the exact balance of unobligated funds and may not reflect unliquidated obligations.  There must be no discrepancies between the final FFFR expenditure data and the total drawdown amount.

Investigators coming to UTHSC with an active award should coordinate with their previous institution and their new Department Administrator on the transfer application that will need to be submitted to the sponsoring agency for the grant to be awarded to UTHSC.  The previous institution must relinquish its award so it can be issued to UTHSC or be granted permission from the sponsoring agency to issue a new subaward to UTHSC. Before a UTHSC account can be created, the newly issued award or new subaward needs to be reviewed, possibly negotiated, and accepted by an official Authorized representative of the University. All required documentation must be routed via Cayuse database system for approval.

If the new UTHSC investigator brings equipment to UTHSC, they will need to 1) work with their old institution’s Sponsored Programs to obtain any required approvals for transferring the equipment to UTHSC, and 2) work with their new Department Administrator to get the incoming equipment properly recorded into UTHSC’s financial system.

To initiate a transfer, The PI must contact their Department Chair and work with their Department Administrator to submit an official request letter with the associated equipment form for approval from the Department Chair, the Dean of the College, and the Senior Associate Vice Chancellor for Research.  

The Department Administrator will work with the PI to ensure that the following requirements are met:

• Cost sharing requirements: Determine if these have been met and whether any unmet requirements will be transferred.
• Equipment purchased: Produce a list of equipment purchased on the current award (cost, acquisition date, property tag number, and funding source) and obtain approval to authorize the transfer.
• Subrecipient: Inform the collaborator of the move.  Determine the status of the subrecipient’s part of the project.
• Material and Data transfer: work with your Department Administrator to initiate an MTA, if needed.
• IRB and IACUC protocols: Closeout protocols at UTHSC and ensure protocols are satisfied at the new institution.
• Co-PI: Determine the role of the Co-PI that will remain at the old institution and if a subrecipient agreement for him/her will be required.

UTHSC must submit a transfer request to the sponsoring agency using the process defined by the sponsor. If the sponsor approves the request; the sponsor will begin the process of closing out the award at UTHSC. Simultaneously, UTHSC will submit a proposal to the sponsor for the remaining funds. Once the closeout and proposal review are completed, the sponsor will grant a new award to UTHSC. The duration of this process can vary from 2-3 months or more, depending on the sponsor. Therefore, it is crucial to initiate the request well in advance of the new expected start date.

If a departing PI intends to transfer equipment items to his/her new institution, certain approvals are required by the University. 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.

When a PI transfers to another educational institution and wishes to transfer University or federally owned property, she/he must furnish a written request for approval to the department chairperson. The PI should fully justify the request and include a list of items to be transferred. All property, regardless of value or original cost must be approved prior to transfer out of UTHSC.  A representative at the receiving institution’s business office 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 CBO’s office.  In addition, the external funding sponsor may need to authorize the University to transfer the property.  

If an award has not yet been made to the University but the PI has received the intent to fund, the program office may handle the transfer “behind the scenes” by manually processing the award transfer. In this case, OSP may be asked to complete a cover page and/or other forms to be provided to the program officer along with the budget information. Just as with any project, the PI must obtain approval from the Chairperson, Dean of College, and Senior Associate Vice Chancellor for Research.

If the award is to stay with UTHSC, the Department Administrator in collaboration with the PI will propose a new PI for the award. The Office of Sponsored Programs will submit the request to the sponsor for approval. If approved, the sponsor will issue a revised notice of award naming the new PI.  

The following information is required to submit to the sponsor:

• An official statement from the PI/Chairperson/Dean stating the reason/benefit of retaining the award and showing how the new PI selected is suitable to continue the project.
• The biographical sketch of the individual proposed as the new PI.
• Other sources of support for the new PI.
• Any budget or cost center changes resulting from the proposed change.
• If applicable, any change in level of effort (a reduction of 25% or more must be reported).

Early termination is the process required to end an award before the published expiration date.  Approval from the Chairperson, Dean of the College, and the Associate Vice Chancellor is first required.  Upon receipt of an official request letter with the appropriate signatures, the request would be submitted to the sponsoring agency for approval. An award can then be terminated early given prior written approval from the sponsoring agency.  

A common reason for terminating an award early would be the departure or transfer of the PD/PI to another institution/organization. There are several other reasons may terminate prior to the original expiration date, due to:

• Accelerated rate of spending exhausts sponsored funds.
• Sponsor’s level of funding is reduced.
• Sponsor requests termination
• Sponsor sends a stop work order or Notice of Suspension

NIH awards require that prior approval be requested and approved at least 90 days before the anticipated termination date of the award.  

If a PI wishes to close a study rather than transfer responsibility to a new PI, the following should be considered:

• All data and records, including regulatory documentation and participant files, should be retained per the University’s retention policy.
• The study should be closed in eIRB through a continuing review application.

Important: In the event of early termination, all required reports, such as financial, technical, and patents, must still be provided to the sponsor.