PI Change in Affiliation (Leaving SBU): Termination or Transfer

When a faculty member who is serving as Principal Investigator (PI) of a sponsored research award transfers to a new institution, SBU must determine whether the award will be relinquished, transferred, or retained under a different PI. In all cases, the departing faculty member must complete certain closeout tasks relating to their awards, (e.g.,  Final Report preparation, final financial expenditures, and Effort Reporting) before their departure.  The PI will need to follow both SBU and sponsor’s specific guidelines for terminating or transferring their sponsored research award.  If circumstances dictate that the PI’s sponsored research awards will be transferred to the PI’s new institution, it is important to review the sponsor’s written guidance, as the process for this type of action will vary by sponsor.  

The SBU Department Admin and/or the PI are encouraged to use the Outgoing PI Award Tracker to identify and coordinate the tasks needed to transfer an award. The Google Sheet should be shared with the OSP Grants and Contracts Post Award team via osp_postawards@stonybrook.edu in order for all parties to keep track of the actions required for each award transfer.. 

In general, the first step should be to contact OSP Grants and Contracts Post Award team via osp_postawards@stonybrook.edu and to submit an Award Modification Request in myResearch Awards for each individual award that requires termination or transfer  (select Transfer to New Institution or Early Termination). The Post Award team or the OSP Specialist that receives the request will verify the information, will run an internal report of all proposals and awards affiliated with the PI, and will coordinate internally the assignment, questions and follow up communications. OSP will provide guidance on each sponsor’s requirements for terminating or transferring an award and ensure that the University’s policies are followed. Typically, award transfer and/or terminations require the combined efforts of the PI, the sponsor’s representative, the PI’s department, OSP, Office of Grants Management (OGM), and, when transferring a sponsored award, contract and grants personnel from the PI’s new institution. The contract team will provide guidance once they receive the Award Modification Request in myResearch for any contracts that may require transfer, early termination or change in PI.

• Action Required by the PI Prior to Transferring Grants and Contract Awards
  • Contact the SBU Department Chair for prior approval.
  • Notify OSP Post Award about the transfer request(s) to be made and include the Outgoing PI award tracker sheet
  • Submit an Award Modification Request in myResearch Awards for each sponsored award that is being transferred that includes the signed relinquishment (see bullet below for required elements in the letter).
  • Review the original award documentation for the following information:
  • Cost sharing requirements: Determine if these have been met and whether any unmet requirements will be transferred.
  • Equipment purchased: Produce a list of all equipment and inventoried items  requested for transfer to include  cost, acquisition date, property tag number and funding source and obtain approval from the Department Chair and the Director of Office of Grants Management to who must authorize the transfer prior to removal from campus property. Use Property Status Change Request form found on Property Control Department link below.
  • Subrecipient: Inform collaborator of move. Determine status of the subrecipient’s part of the project.  
  • Material and data transfer: Work with SBU IPP and the new institution to initiate a Material Transfer Agreement (MTA), if needed.
  • IRB, IBC and IACUC etc. protocols: Close out protocols at SBU and ensure protocols are satisfied at the new institution.
  • Co-PI: Determine the role of the Co-PI that will remain at SBU and if a subrecipient agreement for him/her will be required.
  • Create a Relinquishment Letter (see Appendix A) which will document the following information:
  • The effective date of termination.
  • The name of the new institution.
  • List of awards requesting to be transferred and awards to remain.
  • List of equipment requesting to be transferred.
  • List of actions that might need to be taken for each departure.  
  • Signature line for PI/Dean/Chair approval of transfer of funded project and equipment.

  In addition to this Letter, PIs should create a checklist of actions that apply to sponsored research related actions (see Appendix B - Departure Questionnaire and Considerations When a Principal Investigator Leaves SBU).

  • The PI is encouraged to create an incoming letter for the new institution. If standard statements and forms are not available, the letter should document the following information:
  • The effective start date at the new institution.
  • The name of the old institution.
  • List of grants to be transferred.
  • List of equipment/material to be transferred.
  • Any other relevant information that will help the new institution to facilitate the transfer. The PI must submit to their new institution all required agency forms and reports for the transfer.

PIs may, in some cases, retain an appointment (e.g. unpaid research, voluntary, adjunct, emeritus faculty) at SBU which could allow them to continue overseeing their active awards. While generally acceptable, it is at the discretion of the Chair and the consent of the Dean, to agree to the retention of the PI status especially if the research involves human subject or animal activities. 

If the faculty member leaving SBU is a Co-Investigator who will no longer be working on the project, the PI should contact OSP Post Award to receive Sponsor specific guidance as to how to proceed with removing the Co-Investigator from the award. If the SBU Co-Investigator will continue to work on the project under the auspices of the new institution, the SBU PI will need to take steps to enact a subaward agreement with the new institution. In either case, an award modification request in the myResearch Awards is required to capture these personnel changes.

 

• Special Considerations for PIs conducting clinical research studies

  When leaving SBU the PI is required to arrange timely transfer of responsibilities to the new institution, or, if relevant, within the institution. This is of special importance in clinical research studies which include medical treatment interventions. It is rarely possible to transfer subjects on a specific protocol to the same active protocol at a new institution. If this is not feasible, a new PI must be named at SBU to complete the study at our SBU School of Medicine. Investigators should work with division and departmental chairs to ensure a careful transfer of responsibilities and care of subjects. Alternatively, it may occasionally be necessary to stop subjects' participation and transition them to new clinical care providers. These activities should be undertaken putting the interests of subjects/patients first. These activities should be completed BEFORE the PI leaves the institution. 

 

• Equipment Transfers

  If a departing faculty member intends to transfer RF owned equipment items to his or her new institution, approval must first be obtained from Department Chair and ultimately by the Diretor of the Office of Grants Management. 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. Additional information and Property Status Change Form can be found at Procurement - Property Control. 

• Transfer of Data

  If a departing faculty member intends to transfer data to their new institution certain approvals or agreements may be required.  Faculty should contact OSP and OSP will coordinate other campus offices that may also be involved (e.g., DoIT, Office of Research Compliance, Research Security, IPP). OSP will review the request and determine if an agreement or written permission is required before the data are transferred to a new institution.  If required, OSP will draft the appropriate agreements and send them to the new institution for review and execution.  As a reminder, Stony Brook University owns University Data - seeSBU's Research Data Ownership, Retention and Access Policy. 

  Data that often require an agreement include, but are not limited to, the following: 

  • Data provided by a third party to SBU under a Data Use Agreement
  • Data collected at SBU or generated using SBU funds that include any of the following:
  •  Individually identifiable health information or protected health information (“PHI”); 
  • Personally identifiable information (“PII”) being shared beyond the parties named in the formal agreement or contract that governs the transfer of the data, or in the SBU IRB-approved informed consent;
  • Student information derived from education records that are subject to the Family Educational Rights and Privacy Act (“FERPA”); 
  • Data that are controlled by laws or regulations other than or in addition to those listed above; 
  • Data obtained from an individual or organization under obligations of confidentiality; 
  • Data whose storage, use and transfer must be controlled for other reasons (e.g., Risk Level 3 data that will be shared with anyone outside of SBU, or proprietary concerns) 

  Note: Data that require an agreement may not be transferred without a fully executed agreement. Please contact osp_contracts@stonybrook.edu for non-patient data transfer agreements. Transfer of patient data is managed through SBM - HIPAA Privacy Office. 

• Transfer of Materials

  If a departing faculty member intends to transfer tangible research materials (e.g., animal models, cell lines, specimens, plasmids, antibodies, etc.) to their new institution certain approvals or agreements may be required.  Faculty should contact SBU’s Intellectual Property Partners (IPP) and IPP campus offices that may also be involved (e.g.,   DoIT, Office of Research Compliance, Research Security, OSP). IPP will review the request and determine if an agreement or written permission is required before the materials are transferred to a new institution. IPP will draft the appropriate agreements and send them to the new institution for review and execution.  Learn more about the relevance of MTAs and IPP’s resources on the IPP website.

  Materials that often require an agreement include, but are not limited to, the following:

  • Materials developed in the outgoing faculty’s lab while at SBU
  • Materials developed by other faculty at SBU.
  • Materials developed using SBU funds.
  • Materials received from a third party under a Material Transfer Agreement
  • Materials purchased from a repository under a Material Transfer Agreement or other terms of use. 

  Note: Materials that require an agreement may not be transferred without a fully executed agreement.Please contactsbu_mta@stonybrook.edu for Material Transfer Agreements. 

• Export Controlled Equipment/Technical Data & Licenses
  • If you have been part of a project that is subject to  a Technology Control Plan or Project Management Plan , you must contact  the Research Security Program prior to leaving the institution to discuss the close out of the plan and/or transfer of the controlled technology, information, materials, or item (“technology”) to another PI at SBU or to your new institution.
  • If you have any trainees from comprehensively embargoed countries who are staying at  SBU but are transferring to a new supervisor/PI, contact the Research Security Program to discuss.
  •  If you are leaving the University to go to a new institution outside the U.S., please note that the transfer or export of technology, hardware, materials, research tools or items (“technology”) to your new institution abroad may require an export license. Contact the Research Security Programas far in advance as possible to discuss what technology will be exported.
• Conflict of Interest (COI)
  • If you have a study or project that is subject to a  Conflict of Interest (COI) management plan at SBU, prior to leaving the University, you should contact the Research Security Program to discuss the closure of your COI management plan. If you are planning to transfer the grant(s) under COI management to your new institution, you should contact your new institution’s COI office.
  • Conflicts of Interests that are managed in connection with Public Health Service (including NIH) or Department of Energy funded research, require annual reporting to the federal sponsors. If you are transferring grants to your new institution, this reporting requirement will also transfer to your new institution.
  • After you have left SBU, if you continue to work as a Researcher on research grant(s) at SBU through an adjunct or visiting appointment (not under a subcontract to your new institution), you will continue to be subject to SBU’s Disclosure of External Interests & Commitments Policy. Specifically this means that you will continue to maintain your Disclosure Profile and annual certification  and COI training obligations at SBU. Important information regarding COI reporting and training requirements will be communicated to your SBU email address. Therefore, please ensure that your SBU email is linked or will be forwarded to your new institution’s email.