PI Changes in Affiliation and Absences from a Sponsored Project

The following guidance is provided to assist principal investigators (PIs) and departments take the proper steps when a PI’s relationship to UC Berkeley changes and/or when a PI must be absent from a sponsored project temporarily or for a longer period of time.

PI Change in Affiliation (Joining UCB)

PIs who are transferring to UC Berkeley from another institution and wish to also transfer their active grants/contracts to UC Berkeley should follow this process:

Prior to the PI’s appointment start date the PI should obtain a CalNet ID. (Three to four months lead time is recommended.) The PI will need to work with their Berkeley Regional Services (BRS) RA (or other assigned Berkeley administrative staff) to obtain this ID and follow other subsequent steps in this process.

Before an award transfer can take place, the PI’s current/previous institution must relinquish the award with the sponsor’s approval, and the transfer balance must be finalized by the PI’s current/previous institution. After the award has been relinquished, the PI will need to work with their BRS RA/Other Administrative Staff to upload an “Award Transfer Proposal” into UC Berkeley’s Phoebe system. Compliance issues should be noted on the Special Review/Questions tabs in Phoebe. Also note in the Phoebe record the plan for the transfer. (BRS/Other Administrative Staff will assist the PI with this step.)

The Award Transfer Proposal should include:

The original RFP or link to the funding announcement
The full original proposal.
A truncated scope of work with just the remaining work to be carried out at UC Berkeley, or a new scope.
A project budget for the remaining funds being transferred.

Include documentation of the sponsor’s Indirect Cost Policy if applicable
For federal proposals, UC Berkeley’s federally negotiated F&A and composite fringe benefit rates should be applied to the budget. Note: If a sponsor will not accept UCB’s rates, SPO will negotiate as necessary.
Any other costs as applicable in accordance with UC Policy

Documentation of any cost-sharing commitments made at the proposal stage that will be assumed by UC Berkeley
If subawards are involved, provide a complete Subrecipient package (Subrecipient Commitment Form, statement of work, budget and budget justification) for each.
Any correspondence with PI’s previous institution containing relevant background information
Any correspondence with sponsor’s instructions / guidance for submitting the Award Transfer Proposal and/or transferring the award
Contact information for the sponsor

SPO will review the information provided and work with the sponsor as needed to transfer the award to Berkeley and/or negotiate the terms of the award prior to the transfer. To support project activities during the transfer, a Fund Advance may be requested by the PI with UC Berkeley departmental approval.

Note: Sponsor requirements vary. Please follow these specific guidelines for NIH and NSF award transfers:

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

When a PI plans to move to a another institution and to dissolve his or her affiliation with UC Berkeley, the PI will need to either terminate their active sponsored projects or transfer (with the sponsor’s approval) these projects to their new institution.

The PI will need to follow the sponsor’s specific guidelines for terminating or transferring his or her sponsored projects. The first step is always to submit an Award Action Request to SPO. SPO will provide guidance on each sponsor’s requirements for terminating or transferring a project. This usually involves special paperwork and institutional approvals. SPO also will ensure that the University’s policies are followed. Typically, such actions require the combined efforts of the PI, the sponsor’s representative, the PI’s department, SPO, Contracts and Grants Accounting, and, when transferring a sponsored project, contract and grants personnel from the PI’s new institution.

PI Leave of Absence (Retaining Active UCB PI Status)

If the PI is going to take a leave of absence from UC Berkeley but will retain his or her UC Berkeley PI status, the PI may choose to continue to manage their active sponsored projects through UC Berkeley as long as the PI will be able to successfully supervise the projects and be actively involved from a remote location. PIs should consult with SPO if such a leave will impact the PI’s level of effort on the project. See Reduction in PI/Co-PI Effort for additional guidance on changes in PI effort.

PI Absence from Project (Unable to Retain Active PI Status)

When a PI is going to be “absent” from their sponsored projects, i.e., not able to manage the projects even from a remote location, the PI will need to follow the sponsor’s guidelines about reporting and managing the absence.

NSF

NSF has very specific guidance on this. For a short term absence (less than three months), SPO is required to notify NSF as soon as SPO is aware of the absence and provide a plan for managing the project during this short period of time. For a longer period of absence (more than three months), SPO must notify NSF, provide a plan for managing the project during the PI’s absence and obtain NSF approval of the plan. If a PI plans to be absent from an NSF project, please submit an Award Action Request to SPO as soon as possible and provide the beginning and ending dates of the period of absence and a description of the how the project will be managed during the PI’s absence.

Substitute PI Option

If the PI is going to be absent from the project and wishes to appoint a substitute PI to manage the project during the original PI’s absence, SPO must obtain the approval of the new PI from the sponsor. SPO must also obtain internal approval from the Chair/Dean/Director of the original PI’s department/unit as well as the Chair/Dean/Director of the substitute PI’s department/unit, if different from that of the original PI.

Obtaining Sponsor Approval

The original PI should draft a letter to the program officer seeking approval for a substitute PI and send the letter to SPO via an Award Action Request. (The substitute PI should have no reportable conflicts of interest relative to the project.)

The letter should:

Describe the reason for the original PI’s absence from the project and the need to continue the project under the direction of a substitute PI.
Include information about the new PI’s background, qualifications, available facilities, and ability and willingness to manage the project through the anticipated absence end date.
Include the following certification statement from the substitute PI:

Substitute PI Certification: I am not debarred, suspended, or proposed for debarment or suspension by any agency of the U.S. Government, and I agree to accept the role of PI and the responsibility for the scientific conduct and financial oversight of the project entitled, (insert title of project). I agree to provide all reports required by the sponsor according to the timelines specified in the award.
Provide the signatures of the original PI as well as the substitute PI at the bottom of the letter.

Obtaining Internal Approval

The Chair/Dean/Director of the original PI’s unit should then send SPO an email message stating the following:

I approve the transfer of PI status for the project entitled (insert title of project) awarded to UC Berkeley by (insert name of sponsor) from (insert name of original PI) to (insert name of substitute PI).

If the substitute PI is from a different academic or research unit, the Chair/Dean/Director of the substitute PI’s unit should send SPO an email message stating the following:

As the individual responsible for (insert substitute PI’s academic/research unit), I approve the transfer of the responsibility of the project entitled, “(insert title of project),” to my unit under the supervision of (insert name of substitute PI). My unit accepts responsibility for the conduct and administrative oversight of the project.

After these approvals are obtained, SPO will request all required conflict of interest forms from the substitute PI and endorse and submit the letter to the sponsor on behalf of the University. (For NSF, this will be through FastLane.)

In such cases PIs should be aware that there is no guarantee that sponsor approval will be forthcoming.