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Decision Tool for Determining Where External Grants and Contracts Are Held

Who This Tool Is For

This decision tool is intended for health researchers in London whose research involves one or more of these partner institutions: 深夜福利站, London Health Sciences Centre/London Health Sciences Centre Research Institute (LHSC/LHSCRI), and/or St. Joseph’s Health Care London/Lawson Research Institute (SJHC/LRI). The tool is designed to support researchers whose projects involve hospital-based research, shared research environments, and/or cross-institutional collaboration. The decision tool will also be used by research administrators at all three partner institutions to help determine where research funding should be held.

When to Use This Tool

This tool is intended to be used early in the external grant or contract development process, ideally prior to submission, to help researchers determine where funding should be held. This determination is based on identifying the institution that represents the primary centre of activity, responsibility, and risk for the research. Using this tool early is intended to:

  1. Reduce uncertainty at the submission stage;
  2. Avoid delays in institutional authorization;
  3. Support efficient coordination between partner research offices; and
  4. Minimize delays in post-award funding activation.

This tool applies to new grant applications or new contracts only. Existing grants and contracts will not be impacted.

How Decisions Are Made

This tool is designed to support researcher self-assessment and early guidance. Final determination and authorization of where a grant or contract is held rests with the institutional research offices at 深夜福利站, LHSCRI, and LRI, in alignment with the Affiliation Agreements and joint institutional processes. Where needed, decisions will be made through collaborative institutional assessment and joint guidance, as reflected in Step 5 and in the FAQ.

Using the Tool

With this context in mind, researchers can use the steps below to guide early planning for where new research funding should be held.

Decision Tool

Step 1: Funder Requirements* & Eligibility

Does the funder specify where the grant or contract must be held, and/or can the requirements of the funding agency be met by the lead institution?

Example: Some funders require grants to be held at specific types of institutions (e.g., university-only or hospital-only), or require institutions to meet specific administrative, legal, or financial compliance requirements. Relevant examples include NSERC, SSHRC, and Horizon Europe, which currently can only be held at 深夜福利站.

 

Step 2: Primary Location of Research Activity

Where is the majority of the research activity being conducted?

Consider aspects such as:

  • ­Physical laboratory or clinical space
  • Location of infrastructure
  • Core facilities (e.g., ‘omics, pathology, imaging, animal, biobank, simulation, etc.)
  • Participant recruitment and visits
  • Data collection and data storage*
  • Data analysis (including data coding, use of secondary data, etc.)

Step 3: Staffing and Day-to-Day Operations

Where are the majority* of personnel who are carrying out the work employed and operationally managed?

Consider aspects such as:

  • ­­Employment of research staff (coordinators, technicians, assistants)
  • Study activities of trainees (recognizing they are typically university-employed)
  • Location of day-to-day supervision and operational management
  • PI appointment (a consideration, not determinative )

Step 4: Research Risk Assessment (Tie-Breaker)

The location of higher-risk research activity determines institutional accountability and responsibility, including liability and risk management considerations.* This is particularly important for research involving human participants (patient and non-patient populations), regulated materials, and/or hospital-controlled systems.

For higher-risk and/or human participant research, where do the following activities primarily occur?

Direct human participant interaction 
(recruitment, consent, procedures, follow-up visits)
Interventional or higher-risk study activities with patient populations*
(clinical trials, device/drug interventions, procedural changes, regulated materials)
Use of hospital-controlled clinical space, infrastructure, or clinical systems*
Hospital-based safety monitoring, adverse event reporting, or regulatory obligations*

Decisions Tool Assessment

When to Seek Guidance

If your project involves multiple institutions or other complex scenarios, see the FAQ for additional guidance.

Researchers are also encouraged to consult their relevant institutional research office(s) early in the grant or contract development process/before submission if:

  • The centre of research activity is unclear;
  • The project is evenly split across institutions;
  • You need assistance in interpreting and/or assessing considerations in Step 4, particularly risk-related considerations; and/or
  • There is disagreement between partners.
Joint guidance between 深夜福利站, LHSCRI, and LRI will be provided to ensure consistency. If you have questions and/or require additional support, please reach out to institutional research teams:

Definitions & Frequently Asked Questions

Clear Majority: Defined as ≥60% of the research activities, staffing, and day-to-day operations taking place at a particular institution. (back to step 3)

Financial Administration & Payroll: Refers to which institution is responsible for managing the research funds, including budgeting, financial reporting to funders, and paying salaries for research staff. This does not require that all research activity occur at that institution but rather reflects where financial accountability resides.

Funder: Refers to the person, funding agency, or contract funding partner providing funds for the research.

Funder Requirements: Refers to the fact that some funders require grants or contracts to be held at a specific type of institution (e.g., university-only or hospital-only), or require the institution to meet specific administrative, legal or financial compliance requirements in order to hold their funding. These requirements are non-negotiable and override institutional discretion. When this applies, the grant or contract must be held at the eligible institution, with appropriate sub-grant/transfer of funds arrangements put in place as needed. (back to step 1)

High-Risk Study Activities: Refers to research activities that involve direct patient interaction, interventional procedures, clinical decision-making, use of hospital-controlled clinical environments, or regulatory obligations related to participant safety (e.g., adverse event reporting). This does not apply to minimal-risk observational research, retrospective chart reviews, surveys, or secondary data analysis conducted outside hospital-controlled clinical environments. The presence of human participants alone does not determine funding location. (back to step 4)

Hospital-Controlled Clinical Space or Systems: Refers to inpatient units, outpatient clinics, operating rooms, procedural suites, or other environments where the hospital maintains operational control and responsibility for patient care and safety. This also includes hospital-managed clinical information systems (e.g., electronic medical records) and infrastructure that are governed by hospital policies and oversight. Use of hospital-controlled space or systems is an important consideration in determining institutional accountability under Step 4. (back to step 4)

IT Systems, Data Storage, & Security: Refers to which institution’s IT platforms and data systems are used to store, manage, and secure research data. This includes responsibility for data protection and access, as well as compliance with privacy and security requirements. (back to step 2)

Liability, Insurance, & Risk Management: Refers to which institution would be primarily accountable if an issue arose during the conduct of the research. This includes responsibility for insurance coverage, managing incidents or complaints, and addressing potential harm to participants, staff, or the institution. These considerations are particularly relevant for research involving animals, patients, clinical procedures, regulated materials, and/or hospital-controlled systems. Researchers are not expected to be experts in institutional risk, and research offices will provide guidance and support where needed. (back to step 4)

LHSCRI: Refers to London Health Sciences Research Institute.

LRI: Refers to Lawson Research Institute.

Regulatory & Compliance Oversight: Refers to which institution is responsible for ensuring that the research complies with applicable laws, regulations, and policies, such as ethics approvals, privacy requirements, and regulatory reporting. This typically aligns with the institution that authorizes and oversees the conduct of the research. (back to step 4)

Study-Related Operating Costs: Refers to where the day-to-day costs of conducting the research are incurred, such as supplies, services, participant-related costs, or core facility fees. These costs usually align with where the research activities are physically carried out.

Sub-Grant/Transfer of Funds Agreement: Refers to a formal mechanism that allows funds from a grant or contract held at one institution to support research activities/expenses at another institution. Sub-grants/transfer of funds agreements are commonly used when research activities and costs span multiple institutions and are supported by the University and Hospital partners. These sub-grants/transfer of funds agreements can be bi-directional, e.g., either university → hospital or hospital → university. The current sub-grant/transfer of funds agreement process will be streamlined to facilitate this in a manner that limits administrative burden.

深夜福利站: Refers to 深夜福利站.

This change is being introduced as part of the renewed Affiliation Agreements between the University and Hospital partners, which establish a shared principle that research funding should be held at the institution where the majority of the research is conducted and supported. The partner institutions recognize that research support services are a critical part of researchers’ experience and success, and that access to equivalent research support services, along with strong cross-institutional coordination, is essential for a well-functioning research environment. For this reason, implementation is being approached deliberately and collaboratively through a “soft launch” beginning in March 2026. During this phase, researchers will be encouraged to use the tool, while institutions gather real-world experience, identify practical challenges, and address operational barriers. Broader implementation will occur only after key issues have been identified and meaningfully addressed, informed by researcher feedback and lived experience. The goal is not simply policy alignment, but a model that is workable, fair, and sustainable for the health research community.

No. Existing grants and contracts will remain with their current administering institutions. The requirement applies to new grant applications/contracts only.

No. Under the updated Affiliation Agreements, grants and contracts must be held at the institution where the majority of the work is done. The only exception to this is if the funder restricts where the funding can be held. When this applies, the funding must be held at the eligible institution, and sub-grants/transfer of funds agreements can be put in place if work occurs elsewhere.

Under the Affiliation Agreements, funding must be held where the majority of the research is taking place. Therefore, in cases where a researcher is awarded a grant but applied through the incorrect institution, the relevant research office(s) will work with the funding agency to have the award moved to correct primary institution, wherever possible.

No. A PI’s primary appointment (深夜福利站, LHSCRI, or LRI) does not determine where the grant or contract should be held. The determination is based on where the research is conducted, how it is operationally managed, and which institution has primary responsibility and oversight for the work.

This is common. In these cases, the location and nature of the research activities (not the PI’s employer) determines where the grant or contract should be held. University-employed PIs may appropriately hold hospital-based grants or contracts when the centre of research activity and responsibility lies at LHSCRI or LRI.

In projects where activities span institutions, the funding should be held at the institution where the majority of research activity and higher risk accountability resides. When higher-risk or interventional clinical activities occur within hospital-controlled environments, the hospital will typically hold the award. Sub-grants can be used to support work occurring at partner institutions.

If the majority of the work and associated risk/responsibility reside at one hospital, the grant or contract should generally be held there. If the work and responsibility are evenly split, the applicable hospital-hospital collaborative agreement will guide the determination. Sub-grants/transfer of funds agreements can be used to support work at the non-holding institution. Contact the research office at the institution where the main grant or contract is held in order to request a sub-grant/transfer of funds agreement.

In general, grants or contracts for clinical trials taking place within the hospitals setting and/or using hospital resources should be held at the hospital, since the hospitals typically assume primary responsibility for patient care, trial conduct, regulatory oversight, and safety reporting. Exemptions may include community-based clinical trials or those that are conducted at 深夜福利站. If you are unsure whether your study fulfils this criteria, your institutional research office(s) can help clarify.

The involvement of human participants alone does not automatically require that funding be held at a hospital. Minimal-risk, non-interventional, observational, or analysis-only studies may be appropriate to be held at 深夜福利站 if the centre of research activity and responsibility resides there.

For large or multi-component grants or contracts, consider where the dominant share of the budget, personnel effort, oversight, and responsibility resides. It is expected, as per current practice, that a tri-partite agreement or sub-grants/transfer of funds agreements will be used to support work occurring at partner institutions when appropriate.

Minor or limited activities at a secondary institution (for example, data analysis, access to a specific core, or small numbers of samples) do not, on their own, determine where funding should be held. The decision is based on the overall centre of research activity, responsibility, and risk. In cases where study-related costs are incurred at a secondary institution, sub-grants/transfer of funds agreements can be used to support work at the non-holding institution.