Archived in January 2013 Schedule 9: Transfer of Funds From a Primary Institution to a Secondary Institution

This information has been archived. Visit the  Agreement on the Administration of Agency Grants and Awards by Research Institutions page for current information.

1. Definitions

Eligible Institution

Non-eligible Institution

Primary Institution

Secondary Institution

Principal Investigator

Co-investigator

Collaborator

2. Application and General Policy

This Schedule deals with transfers of research funds. Part A and Part B detail the two different scenarios in which funds may be transferred. Part A deals with the transfer from an Eligible Primary Institution to an Eligible Secondary Institution. Part B deals with the transfer from an Eligible Primary Institution to a Non-eligible Secondary Institution (this section only applies to CIHR and SSHRC). This Schedule does not address payment of invoices or contracts or accountable advances; these are not considered to be grant transfers for the purpose of this schedule. Grant transfers include transfers of both funds and responsibilities.

A transfer of funds normally occurs when a Primary Institution, in direct receipt of Agency funds, transfers some or all of those funds to a Secondary Institution in order to facilitate research collaboration between the Grant or Award Holder and the co-investigators at the Secondary Institution; and in the case of CIHR only, with collaborators, research personnel and co-principal investigators at the Secondary Institution.

Under the terms of this MOU and its Schedules, an eligible Secondary Institution has the same responsibilities for grant or award funds transferred to it from a Primary Institution, and for the research supported, as it does when funds are awarded directly to it by the Agencies. A Primary Institution that transfers funds to a Non-eligible Secondary Institution retains all the responsibilities and accountabilities for those funds, and the research supported, as outlined in this MOU and its Schedules. The Primary Institution has additional responsibilities to review and consolidate the Form 300 and to ensure that a letter of agreement with the Secondary Institution is in place before the transfer of funds occurs.

Part A – Transfer of Funds Between a Primary Institution and an Eligible Secondary Institution

3. Roles and Responsibilities

3.1 Responsibilities of the Primary Institution

The Primary Institution that transfers funds to an Eligible Secondary Institution agrees to:

1. prepare, prior to any transfer, a “letter of transfer of funds” agreement to be signed by both Institutions, that identifies the research project, the Grant or Award Holder, any co-investigators and/or collaborators, the period for use of the funds, the proposed use of the funds, the amount to be transferred, the timing of the transfer and when all unused funds must be returned to the Primary Institution.
   
   The letter must also address any necessary clarification on ownership of equipment, adherence to applicable regulations, policies and guidelines, etc., including the specific certification requirements for research conducted at both the Primary and Secondary Institutions (see Schedule 2, 3 and 13);
   
   
2. require that, by April 30 of each year, the Eligible Secondary Institution complete and forward a financial statement (Form 300), signed by its financial officer and the researcher to whom the funds were made available, to the Primary Institution;
   
   
3. review the Eligible Secondary Institution’s financial statement (Form 300) to ensure that the information provided is accurate in terms of the budget amount (or amount of funds transferred), balance forward amount and eligible expenditure categories, in accordance with the letter of agreement;
   
   
4. consolidate the information provided in the financial statement (Form 300) received from the Eligible Secondary Institution with the information of the Primary Institution’s own financial statement to create a single consolidated financial statement for the grant in question; and
   
5. for the purposes of the transfer, maintain the relevant supporting documentation on file (i.e., a copy of the transfer of funds letter and Form 300) from the Secondary Institution.

3.2 Responsibilities of the Eligible Secondary Institutions That Receive Transfers of Funds

The Eligible Secondary Institution receiving the funds agrees to:

1. administer the funds for the benefit of each participating Grant or Award Holder, co-investigators and/or collaborators of that Institution in accordance with this MOU, its Schedules and with any other relevant policies of the Agency, including policies on categories of eligible expenditures;
2. follow the terms of the signed letter of transfer;
3. ensure that all necessary certifications are in place for research conducted under its jurisdiction or auspices (see Schedule 2, 3 and 13);
4. return all unused and uncommitted funds to the Primary Institution at the end of the period agreed to for the use of the funds;
5. complete and forward to the Primary Institution a financial statement (Form 300), signed by its financial officer and the researcher to whom the funds were made available; and
6. maintain the relevant supporting documentation on file (i.e., a copy of the transfer of funds letter, certification(s), supporting documentation for all expenditures and Form 300).

3.3 Responsibilities of the Agencies

Each Agency agrees to:

1. publish on its Web site a list of its Eligible Institutions;
2. include, during regular financial monitoring visits, the review of relevant supporting documentation relating to the transfer and subsequent expenditure of funds; and
3. respond to requests for advice about the consolidation of the financial statements and any other issue related to the transfer of funds.

4. Good Practices

The Agencies’ Manual of Good Practices Observed During Monitoring Visits is available on the Web at: www.nserc-crsng.gc.ca/_doc/NSERC-CRSNG/ManualofBestPractices.pdf.

5. Resolution of Issues of Non-Compliance

In the event circumstances arise in which a Primary and/or Secondary Institution appear to be, or are found to be, in non-compliance with the Agency policy under this Schedule, the Agency will follow the procedures described in Schedule 8 at the entry level appropriate to the situation.

Part B – Transfer of Funds Between a Primary Institution and a Non-eligible Secondary Institution, in the Case of CIHR and SSHRC

6. Policy

An increasing number of Grant and Award Holders are conducting research with researchers, students, and/or research personnel who are affiliated with Non-eligible Secondary Institutions. This part of the Schedule recognizes the legitimacy of transferring funds from Primary Institutions to Non-eligible Secondary Institutions, provided that all such transfers of funds are conducted responsibly and follow good financial management practices, the minimum standards for which are set out in this policy.

7. Responsibilities

The Primary Institution has principal responsibility for the use and monitoring of funds which are transferred to a Non-eligible Secondary Institution. However, this responsibility is to be shared between the Primary Institution and the Non-eligible Secondary Institution under the provisions of the “letter of transfer of funds” agreement set out below.

7.1 Responsibilities of the Primary Institution

The Primary Institution that transfers funds to any Non-eligible Secondary Institution agrees to:

1. put in place, prior to the transfer of any funds, a mechanism – described clearly in a “letter of transfer of funds” signed by both Institutions that establishes an agreement between them – that requires the Non-eligible Secondary Institution’s adherence to applicable Agency policies and acceptance of the responsibilities outlined in section 7.2 of this Schedule;
2. ensure that such a letter specifies:
   1. the necessity to adhere to the relevant Agency policies as published in formal guides, program literature and the MOU;
   2. the permitted uses of the transferred funds (e.g., salaries, purchase or rental of equipment);
   3. the delegation of signing authority for the transferred funds to a co-investigator, and/or collaborator, and/or research personnel at the Non-eligible Secondary Institution¹;
   4. that the Non-eligible Secondary Institution has in place, or has access to, human and animal ethics reviews and controls to ensure adherence to ethics policies that conform with the  Tri-Council Policy: Ethical Conduct of Research Involving Humans and with the guidelines of the  Canadian Council on Animal Care;
   5. that the certification requirements (e.g., biohazards, humans, animals) will be in place before the funds can be accessed by any of those researchers;
   6. that the Non-eligible Secondary Institution will complete and submit to the Primary Institution, by April 30 of each year, a financial statement (Form 300) signed by the relevant financial officer and by the researcher to whom the funds were made available;
   7. that all unused and uncommitted funds will be returned to the Primary Institution at the end of the period allowed for the use of the funds;
   8. that the Non-eligible Secondary Institution will permit the Primary Institution to review its records and facilities in the same manner that, under this MOU, an Agency is permitted to review those of Eligible Institutions; and
   9. that the Non-eligible Secondary Institution must repay to the Primary Institution any funds that are used in a way that does not conform to applicable Agency policies;
   10. that the Non-eligible Secondary Institution will provide each relevant researcher at the Non-eligible Secondary Institution with all relevant information concerning any conditions that the Agency has imposed on the use of the grant or award; and
   11. any clarification on the ownership of equipment if equipment is to be purchased by the Secondary Institution.
3. consolidate the information provided in the financial statement (Form 300) received from the Non-eligible Secondary Institution with its own relevant financial information to create a single consolidated financial statement for the grant in question;
4. have its financial officer sign the consolidated financial statement and, by so doing, certify:
   1. receipt of a signed financial statement (Form 300) from the Non-eligible Secondary Institution for the funds transferred to that Institution;
   2. that the information provided in the financial statement from the Non-eligible Secondary Institution is consolidated with financial information of the Primary Institution, and that this constitutes the consolidated financial statement; and
   3. that the information provided in the consolidated financial statement has been reviewed for compliance with the policies set out in this Schedule, with any other relevant policies of the Agency, including those on eligible expenditure categories, and with any relevant policy of the Primary Institution.
5. maintain the relevant supporting documentation on file (i.e., a copy of the transfer of funds letter and Form 300) so that the documentation is readily available for review during the Agencies’ monitoring visits; and
6. upon the Agency’s request, provide supporting documentation for expenditures related to the transfer of funds.

7.2 Responsibilities of the Non-eligible Secondary Institution Under a Letter of Transfer of Funds Agreement

Under the “letter of transfer of funds” agreement established between the Primary Institution and the Non-eligible Secondary Institution as a condition for any transfer of funds, the Non-eligible Secondary Institution agrees to:

1. ensure accountability for the transferred funds – in particular that the appropriate policies, systems, procedures and controls for the proper management of these funds set out or referred to in this MOU are in place;
2. administer the funds on behalf of the Primary Institution for the benefit of any researcher, including the Grant or Award Holder, any co-investigator, and/or collaborator, and/or research personnel at the Non-Eligible Secondary Institution in accordance with the relevant Agency’s policies as published in their formal guides and program literature and in the MOU;
3. ensure that each of those researchers uses the funds only in the areas permitted in the “letter of transfer of funds” agreement;
4. have in place, or have access to, human and animal ethics review and controls to ensure adherence to ethics policies that conform with the  Tri-Council Policy: Ethical Conduct of Research Involving Humans and with the guidelines of the  Canadian Council on Animal Care
5. ensure that a Human Ethics Certificate and any other relevant certificate are received before the transferred funds are made available to any researcher and that certifications be maintained current;
6. provide to the Primary Institution, by April 30 of each year, a financial statement (Form 300), signed by the financial officer and the researcher to whom the funds were made available. The financial officer’s signature certifies that the funds were administered according to the relevant Agency’s policies and requirements. The Non-eligible Secondary Institution has the right and responsibility to withhold or withdraw approval of expenditures proposed by the researcher if the expenditures do not comply with the Agency’s requirements or with its own Institutional policies. When it is appropriate, the Non-eligible Secondary Institution may seek advice or a ruling from the Primary Institution;
7. return all unused and uncommitted funds to the Primary Institutions at the end of the period allowed for the use of the funds; and
8. maintain the relevant supporting documentation on file (i.e., a copy of the transfer agreement letter, certification(s), supporting documentation for all expenditures and Form 300). In particular, the Non-eligible Secondary Institution must be able to provide the Primary Institution, on request, with copies of documents detailing transactions involving the funds.
   

7.3 Responsibilities of the Relevant Agencies

Each Agency agrees to:

1. publish on its Web site a list of its eligible Institutions; and
2. respond to requests from the Primary Institution for advice concerning the “letter of transfer of funds” agreements that establish guidelines, the consolidated financial statements and any other issue related to the transfer of funds.

8. Good Practices

The Agencies’ Manual of Good Practices Observed During Monitoring Visits is available on the Web at: www.nserc-crsng.gc.ca/_doc/NSERC-CRSNG/ManualofBestPractices.pdf.

9. Resolution of Issues of Non-Compliance With Respect to a Non-eligible Secondary Institution

In the event circumstances arise in which a Primary and/or Non-eligible Secondary Institution appear to be or are found to be in non-compliance with the Agency policy under this Schedule, these will be considered to be issues of the Primary Institution and the Agency will follow the procedures described in Schedule 8 at the entry level appropriate to the situation.

¹As per definition, SSHRC does not allow the transfer of funds to collaborators.