If a PI plans to leave an organization during the course of a grant, the organization has the prerogative to nominate a replacement PI, request that the grant be terminated, or transfer the grant to the PI's new organization. Replacement PIs are subject to sponsor’s approval. In those cases where a particular PI's participation is integral to a given project and the PI's original and new organizations agree, a grant transfer request shall be submitted via the sponsor’s system and/or e-mail.
Prior sponsor approval must be obtained from federal and non-federal sponsors if the PI is terminating or transferring his/her award early before the project ends. Possible reasons for early termination include:
- The PI has expended all of the awarded funding in compliance with the award terms and conditions;
- The PI has submitted all project deliverables;
- The PI is leaving Harvard and the project will not be transferred or assigned to a new PI;
- The sponsor has requested an early termination.
Important to note: In the event of early termination or PI Transfer, all required reports (e.g., financial, technical, property and patent), must be provided to the sponsor. Departments should also be mindful of whether an early termination may negatively impact the sponsor's willingness or contractual requirement to make final payment on outstanding invoices.
Review Award Components
Please review the award for the following components to ensure that all compliance requirements are met according to the terms and conditions of the award.
|Budget||Provide a budget per the sponsor’s guidelines and reconcile account as close as possible to the end of the period and if there are no funds remaining in the award account, but, out year increments remain; determine the final figure or amount to be relinquish to other institution.|
|Cost Sharing Commitments||Note that if the PI's original award was submitted in response to a program solicitation that required cost sharing as part of the award, this cost sharing requirement also must be addressed by the new organization in the budget portion of the transfer request. The cost sharing will be reflected as a condition in the award at the new grantee organization, if applicable.|
|Equipment||Include a list of equipment that is transferring to the new institution, if applicable|
|Effort Reporting||Ensure that all effort for the current PI has been updated in e-cert|
|Export Controls||If project involves export controls follow the export controls guidance and discuss EAR, ITAR, Software, Data Sharing /Data Use Agreements or other issues that may impact the transferring of award.|
|Foreign Institutions||If award is to be transferred to a foreign organization agency, confirm that the sponsor allows awards to be transferred to a foreign institution, if applicable [Non-US Federal Foreign]|
|IACUC Approvals||Additional information may be required for certain types of proposals, such as those involving vertebrate animals. Such proposals may require supplementary documents be submitted in conjunction with the transfer request, if applicable|
|Inventions/Patent Reports||Submit all final patent reports for PI and subrecipients|
|IRB Approval||Additional information may be required for certain types of proposals, such as those that involve human subjects. Such proposals may require supplementary documents to be submitted in conjunction with the transfer request. In addition, ensure that the PI will continue to work on human subject’s research without interruption. This may require that the PI request his IRB protocols be extended beyond the termination date to ensure that IRB requirements are met. Please refer to the IRB policies and procedures. Contact the both respective IRB office for smooth transition of awards.|
|PI Rights and Appointment||Discuss any special circumstances regarding PI rights and appointment with current and other institution|
|Period of Performance (POP)||
Discuss if there will be any gaps in the POP between the time the PI’s appointment ends and PI start at the new Institution, if applicable
|Personnel (i.e., Postdoc & Grad Students)||Discuss how all personnel will be handled or transitioned as part of the early termination or PI transfer, if applicable|
|Relinquishing Statement and/or Final Figure||Complete the relinquishing statement as required by sponsors and reconcile the accounts and determine the final figures, as applicable|
|Reporting Requirements||Ensure that all Final Financial and Progress Reports are submitted to sponsor|
|Subrecipients||If the award has a subrecipient component, issue amendments to terminate subs and request final invoices.|
Roles & Responsibilities
- Notify OSP as soon as possible that the PI is leaving and communicates to OSP any unusual arrangement concerning the early termination or PI Transfer. Most sponsor guidelines require that the notification be received sixty to ninety days prior to the requested date of transfer or termination.
- Review sponsor’s terms and conditions on early termination and PI Transfers
- Complete an Early Termination request and uploads all documentation in GMAS including the Relinquishing Statement Form. Coordinate with the Pre-Award Portfolio Owner and Research Finance
- Verify Final Technical Reports have been prepared and/or submitted and upload these reports or e-mails in GMAS document repository (i.e., Final Progress Report, or other)
- Provide a brief summary of progress to date (Required for most of the sponsors)
- Include a description of work yet to be accomplished (specific to NSF but may be required by other sponsors)
- Identify budget amount to be transferred or relinquished
- Complete and Upload Patent Report Form in GMAS
- Enter the request in the sponsor’s portal and release it to OSP for review and approval, if required
- Lock & Route request in GMAS
- Sign-off on the Early Termination Request in GMAS, as required.
- Discuss internally temporary appointment for PI rights, if applicable
- Note: Department Administrators should not contact the sponsor regarding a transfer or termination without the PI and OSP’s consent
Pre-Award Portfolio Owner (SGCS/GCS/AGCS)
- Coordinate with both the Dept Adm & Research Finance (RF) to arrive at Final Figure
- Review for compliance requirements with the sponsor’s terms and conditions of the award
- Contact sponsor for clarity on behalf of the PI if the terms and conditions do not provide information on early termination or PI Transfer
- Sign-off on the Early Termination Request in GMAS
- Assign Authorized Organizational Representative (AOR) Approver as University Authorized Signatory (UAS) in GMAS. The AOR signs-off on the letter or relinquishing statement form or other support documentation.
- The AOR will certify in coordination with the Pre-Award Portfolio Owner to ensure that all sponsor’s requirements and compliance with the internal and external policies and procedures are adhere to.
- The Portfolio Owner (PO) and/or AOR will submit the signed relinquishing statement to sponsor, as applicable.
- Upload signed documents and locks all documents uploaded in GMAS once everything has been submitted to sponsor
- Follow through to ensure the Early Termination is either approved or formally acknowledged by the Sponsor per their specific guidelines and procedures
- NOTE: Prior Sponsor Approval is required before making any changes in GMAS (i.e. De-obligation of funds and end date)
- Coordinate with OSP Operations on action memo/revision de-obligating any remaining time &/or funding
- Update Non-Financial Reports in GMAS (i.e., Patents), as applicable
- Coordinate with Research Finance to closeout award
Research Finance - Post Award functions
- Check if Final Financial Report, Invoice or Review is necessary and process accordingly
- Confirm Final Figure with department and Pre-Award Portfolio Owner
- Review detailed listing for expenses posted on the GL for CAS (Cost Accounting Standards) compliance
- Review cost sharing commitment, if applicable
- Coordinate and complete any financial deliverables as needed (i.e. - Assignment & Release Forms or Closeout Questionnaires’)
- Prepare financial reports/review as required
- If refund of income or interest is necessary, process refund.
- If interest is retainable, transfer interest to department unrestricted account
- Ensure Info Management is updated to reflect the Early Termination
- Coordinate return or transfer of funds once action memo is complete and de-obligation has been processed internally.
Note: Upon transfer of the grant to the new organization, any monetary discrepancies must be resolved between the original and the new grantee, some sponsors will not intervene in any disputes between the two organizations regarding the transferred amount.
Outgoing Subrecipient Component
- Communication to the subrecipient is essential to terminating the award in a timely manner and provide necessary details about what is needed for the termination
- If the project is being terminated halfway through the awarded period and there are balances that were obligated to subrecipients, an amendment should be created and sent to subrecipient, de-obligating and ending the Period of Performance (POP) accordingly.
- If the award is ending precisely when the subrecipient’s funds has been used and a final invoice provided. The invoice should suffice to terminate the award and enter final figures in GMAS.
What are the most common reasons for Early Termination?
- PI Transfer to another institution
- PI completes project early
- PI ends project early or No longer eligible
- Sponsor Initiated
How does the Early Termination notification get to OSP?
- Sponsor initiated by notifying Department and/or OSP
- PI initiated and notified Department and/or OSP
When OSP is notified of Early Termination, what should happen?
- The Pre-Award Portfolio Owner coordinates with all parties (see Responsibilities section) and ensures that all information is reviewed and submitted to sponsor for approval.
When should the Dept Adm/PI notify OSP when the PI is thinking of leaving or transferring his award?
- The Dept Administrator/PI should notify OSP as soon as possible or 30 days prior to the PI’s last day at Harvard. The Department Administrator should process a request in GMAS for a PI Transfer/Early termination.
Can we retain the balance on the account?
- The terms and conditions of the determines if funds can be retained by Harvard or it should be returned to the sponsor.
Can I terminate the award early in GMAS before we de-obligate the amount?
- It is important that we get sponsor’s prior approval before we can de-obligate and end the project in GMAS.