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Principal Investigators should complete an OSR-4 form for any active grant, cooperative agreement, or contract that they wish to relinquish or transfer prior to the normal project period end date of an existing award. This includes both funded awards and any awards that have been granted "pre-spending" status. Normally, these forms are completed when a principal investigator is transferring to another institution and wishes to take the remainder of an existing grant (current budget period and/or any remaining budget periods within the existing project period) with him/her to the new institution. An OSR-4 form is not required for a new or competing continuation (renewal) proposal that has been submitted but not yet awarded (unless pre-spending has been established.) In the latter case, the Principal Investigator should write a letter to the agency indicating that they are moving to a new institution and submit that letter to OSR for countersignature along with a signed OSR-2 form. The decision to relinquish a proposal or an award is at the discretion of the Department Chair and/or Dean- the Chair or Dean may elect not to permit relinquishment of either a proposal or an award and instead decide that it is in the best interest of the University to propose an alternative principal investigator to the funding agency for the project.
Principal Investigators should prepare and submit an OSR-4 form as soon as they know that they will be relinquishing/transferring the award. Agencies generally need at least 90 days to complete the process of transferring an award from one institution to another. Some agencies, including NIH, will generally not agree to transfer an award within the last six months of a project period, though they may permit the original grantee to issue a subcontract to the principal investigator's new institution to allow completion of the original project. Principal Investigators should consult with their Department Chair if this mechanism is needed, since it will require that either the PI retain a courtesy appointment at Northwestern, or that an alternate principal investigator be identified who will assume custody and oversight of the award at Northwestern during the completion period.
Principal Investigators should review the status of all personnel working on their projects to be transferred to ensure that appropriate arrangements have been made. In general, human resource requirements mandate advance notice (often 30 days) before an employee can be terminated. Recruitment of replacement personnel, if needed, at the new institution should also be factored into the Principal Investigator's timetable. In some cases (particularly graduate students), employees may need to complete work on the project at Northwestern. Various mechanisms to achieve these needs are available, including arranging for a subcontract from the new institution, or arranging for a local investigator to assume day-to-day supervision. OSR is available to consult with PIs about these types of arrangements. PIs should also discuss these needs with their Department Chair.
The Principal Investigator should consult with the Technology Transfer Office immediately if any of the following apply to the funded project: the PI is utilizing intellectual property of a third-party with rights granted to Northwestern under a Material Transfer Agreement or a patent License/Option; the PI has filed an invention disclosure to Northwestern citing the sponsored project; the PI is using a Northwestern-owned invention on the project.
Sponsor requirements for the transfer of equipment vary, and PIs should consult with OSR for determination of the specific requirements for their project(s). In general, sponsors expect that equipment purchased under an existing award will be transferred with the award to the principal investigator's new institution. These items should be listed on the OSR-4 form. Note that this expectation extends only to items meeting Northwestern's capital equipment threshold ($5,000 or more per item, useful life of 1 year or more) and to items that were fully-funded by the sponsor on the current award. Items purchased on the project that do not meet the definition of "equipment" (e.g., many computers, small pieces of equipment), or are co-funded by the University, or were purchased on earlier projects are retained by the University unless approval is otherwise granted by the Department Chair. In some cases, an equitable financial arrangement for transfer of the items may need to be established.
Accounting Services for Research and Sponsored Programs is responsible for preparation and submission of final financial information to the funding agency, working in cooperation with a principal investigator and administering department.
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