Change of Grantee Organization
Prior approval is required for the transfer of the legal and administrative responsibility for a grant-supported project or program from one legal entity to another before the expiration of the approved project period. Grantees will find this information helpful if, and when, they encounter a problem with facilitating the administration of a grant project or program.
The following is an excerpt from HHS Grants Policy Statement.
OPDIV prior approval is required for the transfer of the legal and administrative responsibility for a grant-supported project or program from one legal entity to another before the expiration of the approved project period (competitive segment for grants where there may a competing continuation for the same project). For other changes in organizational status, e.g., a name change, the recipient must notify the awarding office as specified in “Changes in Organizational Status.”
A change of grantee organization may be accomplished under most OPDIV grants, including construction grants, if any of the following conditions are met and the OPDIV determines that the purpose and scope of the approved grant will not change and the transfer is consistent with Federal appropriations law requirements:
- The grant to be transferred has been terminated at the original organization in accordance with 45 CFR 74.61 or 92.43.
- A non-competing continuation award that is within an approved project period has been withheld for a reason other than project performance, e.g., the recipient’s management of the grant or non-compliance with award terms and conditions.
- The original recipient has agreed to relinquish responsibility for an active project before the expiration of the approved project period. This includes any proposed change of grantee as a result of a PI on a research project transferring from one organization to another organization. The project under the same PI may be supported at a new organization for a period up to the remainder of the previously approved project period in an amount not to exceed that previously recommended for direct costs (plus applicable indirect costs) for the remainder of the approved project period.
A request for a change of grantee organization (change of grantee) must be submitted to the GMO before the anticipated start date at the new organization and preferably several months in advance. Failure to provide timely notification may result in disapproval of the request or a delay in processing.
As part of the request, the original organization must submit PHS 3734, “Official Statement Relinquishing Interests and Rights in a Public Health Service Research Grant,” or equivalent form as specified by the OPDIV, and, if the request involves a research grant, a “Final Invention Statement and Certification.” The request also must include an application from the proposed recipient organization. (The relinquishing organization must submit a final FSR to the awarding office no later than 90 days after the end of HHS support.)
The application from the proposed recipient should include the following, as applicable:
- Face page
- Budget pages (current and future years)
- Updated biographical sketches for the PI/PD and existing key personnel and biographical sketches for any proposed new key personnel
- Statement indicating whether the overall plans/aims or objectives have changed from the original submission, and, if so, how
- For research grants
- Updated “other support” pages, if necessary
- Resources page
- Checklist page
- Certification of IRB/IACUC approval, if applicable
- Detailed list of any equipment purchased with grant funds being transferred to the new organization (inclusion of this list in the transfer application from the new organization indicates its acceptance of title to that equipment).
The OPDIV may request additional information necessary to accomplish its review of the request. Acceptance of a relinquishing statement by the OPDIV does not guarantee approval of a transfer application for the continued funding of a project.
A change of grantee request normally will be permitted only when all of the permanent benefits attributable to the original grant can be transferred, including equipment purchased in whole or in part with grant funds. In reviewing a request to transfer a grant, an OPDIV will consider whether there is a continued need for the grant-supported project or program and whether there will be any a change in scope of the previously approved project.
A change of grantee may be made without objective review, provided the PI/PD plans no change in scope and the facilities and resources at the new organization will allow for successful performance of the project or program. If the change involves a change in scope, the request may not be processed as a change of grantee, will require objective review, and may be subject to a different process, e.g., treated as an exception to competition.
A change of grantee that involves the transfer of a grant to or between foreign institutions or international organizations also may require special OPDIV approval, e.g., approval by an Advisory Council or Board. If these conditions or other programmatic or administrative requirements are not met, the OPDIV may require objective review or may disapprove the request and, if appropriate, terminate the award.
The OPDIV will accomplish a change of grantee organization by issuing a revised NoA to the original recipient reflecting the revised budget and project period end dates, deletion of any future-year support, and deobligation of remaining funds, if applicable. (A deobligation of funds will be based on the estimated grant expenditures through the relinquishment date, as determined from the relinquishing statement.)
Concurrently, the new recipient will receive a NoA reflecting the balance reported on the relinquishing statement or, if the change of grantee organization occurs on the anniversary date of the project, the NoA to the new recipient will reflect the previously committed direct cost level plus applicable indirect costs.
This amount is subject to change as a result of the closeout of the original grant and may be adjusted downward. If a change of grantee involves the transfer of equipment purchased with grant funds, the transfer may be accomplished as part of the original recipient’s relinquishment of the grant or HHS may transfer title to equipment to the new organization using its right to transfer title (see “Property Management”).
"Change of Grantee Organization." HHS Grants Policy Statement. DHHS/ACF/OHS. 2007. English.
Last Reviewed: November 2012
Last Updated: July 30, 2015