NIH Change of Grantee Institution: PI Transfers

When a principal investigator accepts a position at a new institution mid-award, the active NIH grant does not automatically move with them. NIH funds an institution, not an individual — the recipient organization, not the PI, is legally accountable for the award. Moving that legal and administrative responsibility to the new institution is a distinct action called a change of grantee institution (also referred to as a Type 7 change-of-institution request), and it requires NIH’s written prior approval before either institution can act as if the transfer has happened. This guide walks through the mechanics on both sides of the transfer — the relinquishing institution’s obligations, the receiving institution’s application, the timeline, and the mechanism-specific rules that trip up transfers involving training grants and fellowships — in more operational depth than a general prior-approval overview covers.

What actually transfers, and what does not

A change of grantee institution moves the grant itself: the remaining budget, the project period, and the administrative record of the award move from the current (relinquishing) institution to the new (receiving) institution. It does not simply reissue the same Notice of Award under a new name. NIH treats the receiving institution’s portion as a new competing segment reviewed on its own merits, assigns it under the existing grant number’s transfer sequence, and applies the receiving institution’s own negotiated facilities-and-administrative (F&A) rate going forward — not the rate the relinquishing institution had negotiated. Unspent, unobligated funds from the current budget period are what actually moves; funds already spent or obligated at the old institution are accounted for separately through that institution’s closeout of its portion of the award.

Whether a grant is even eligible to transfer depends heavily on the award mechanism, covered in its own section below — a standard R01 research project grant transfers differently than an institutional training grant or an individual fellowship, and assuming they all work the same way is one of the most common planning mistakes on both sides of a move.

Step 1: The relinquishing institution’s obligations

The institution the PI is leaving initiates the process. Its Authorized Organizational Representative (or an equivalent signing official) submits, through eRA Commons, an Official Statement Relinquishing Interest and Rights (PHS Form 3734). This form documents:

The PI’s proposed departure date and the date they intend to start at the receiving institution.
An estimated unobligated balance being relinquished from the current budget period, which becomes the starting figure the receiving institution builds its transfer budget around.
A summary of work accomplished under the award to that point.

In addition to the Relinquishing Statement, the departing institution submits a Final Invention Statement (PHS Form 568) covering inventions conceived or reduced to practice under the award while it was at that institution, and, once its portion of the budget period formally closes, a Final Federal Financial Report (FFR) reconciling actual expenditures against what was awarded. If the transfer is happening before a competing application has even been formally awarded, NIH will accept a signed letter in lieu of the PHS 3734 covering the same information.

Equipment purchased in whole or in part with grant funds is a separate line item the relinquishing institution has to resolve. Under the property standards in 2 CFR 200.313 and 200.314, NIH retains the right to direct where title to grant-funded equipment goes at the end of a project; in a change-of-institution scenario, that typically means the equipment transfers along with the project unless the relinquishing institution has a documented reason to retain it (for example, if the equipment is shared core-facility infrastructure rather than dedicated to the transferring project).

Step 2: The receiving institution’s Type 7 application

The new institution submits what NIH calls a Change of Grantee Organization application — commonly referred to by its activity-code suffix, Type 7 — through the Post-Award Administrative Action Announcements listed alongside the standing parent funding opportunity for change-of-institution requests. A complete Type 7 application includes:

An updated budget covering the remainder of the project period, built from the unobligated balance the relinquishing institution reported.
Updated biographical sketches for the PI and any key personnel moving with the project.
A progress report summarizing work completed to date.
A facilities and resources statement describing the research environment at the new institution.
A detailed inventory of any equipment being transferred with the project — including this list in the application is treated as the receiving institution accepting title to that equipment.
Certification of current IRB and/or IACUC approval at the receiving institution, including the applicable OHRP (human subjects) or OLAW (animal welfare) assurance number, for any award involving human subjects or vertebrate animals. NIH does not carry the old institution’s IRB or IACUC approval forward — the protocol has to be reviewed and approved under the new institution’s own assurance before the transfer can be approved.

If the receiving institution has never held an NIH award before, this application is also where its first-time institutional registration has to be in place: an active SAM.gov registration, an eRA Commons institutional profile, and a negotiated F&A rate agreement (or an interim rate agreement, in the near term) with its cognizant federal agency. None of that can be assembled at the last minute; institutions bringing on a new PI who is also their first NIH-funded investigator should start that registration well before the transfer request itself.

Timing: why three months is the working minimum

NIH recommends the relinquishing institution notify the awarding Institute or Center at least three months before the intended transfer date. That lead time exists because a Type 7 application gets substantive review, not a rubber stamp — the receiving institution’s facilities, budget, and compliance documentation all have to be evaluated, and processing can run longer around federal fiscal year-end (September 30) when awarding offices are working through a higher volume of year-end actions. PIs and administrators who start the paperwork after an offer letter is signed, rather than as soon as a move is realistically likely, are the most common source of transfer delays.

Two timing situations deserve specific attention:

Transfers requested during an active no-cost extension are generally disfavored and are typically not approved except in unusual circumstances. If a PI’s move coincides with a project that is already in, or approaching, a no-cost extension, that needs to be raised directly with the Program Officer and Grants Management Specialist before a formal transfer request is submitted, not discovered as a problem after the fact.
Transfers close to a competing renewal deadline add a second layer of paperwork: the receiving institution may need to coordinate both the change-of-institution request and the renewal application, and the two processes are reviewed on different tracks even though they affect the same project.

Mechanism matters: not every award transfers the same way

The change-of-institution process above describes a standard research project grant (the R-series, most cooperative agreements, and similar investigator-initiated awards). Several other mechanism families follow materially different rules:

Institutional training grants (T32, T34, and similar T-series awards) are awarded to the institution to run a training program, not to a specific PI to conduct a specific project — the institution, not the individual trainee or program director, is NIH’s actual recipient. As a rule, a T32 does not transfer with a departing program director the way an R01 transfers with a departing PI; the institution retains the award and typically names a new program director, while trainees already enrolled are handled according to the awarding Institute or Center’s guidance rather than through a Type 7 request.
Individual fellowships (F30, F31, F32) and some career development (K) awards are made to support a specific individual’s training or career development and use their own relocation/transfer request process rather than the institutional Type 7 mechanism — the fellow or awardee, sponsor, and both institutions coordinate directly with the awarding Institute’s training office, and the specific documentation required varies by Institute. Confirm the current process with the assigned program contact before assuming the standard Type 7 steps apply.
Multi-PI awards where only one of several PDs/PIs is moving require an updated Leadership Plan alongside the transfer paperwork if the departing PI’s role changes materially, since NIH’s multi-PI policy requires the Leadership Plan to reflect who is actually leading which component of the project. See our guide on the NIH Multiple PD/PI Leadership Plan for what that plan needs to cover when responsibilities shift.

What can go wrong

The most common failure points in a change-of-institution request are administrative rather than scientific:

Late notification. Waiting until a PI has already left the old institution to start the paperwork leaves a gap where neither institution has clear authority to spend against the award.
Incomplete equipment accounting. Disputes over which equipment transfers and which stays as shared institutional infrastructure are easier to resolve before the Type 7 application is submitted than after.
Missing IRB/IACUC re-approval. A receiving institution cannot assume the old institution’s human-subjects or animal-welfare approval carries over; if that re-review has not started early, it becomes the pacing item for the entire transfer.
Assuming a training grant or fellowship transfers like an R01. As covered above, these mechanisms have their own rules, and treating them as a standard Type 7 case wastes time and can produce an application NIH cannot act on as submitted.
Overlapping the transfer with a no-cost extension or renewal without flagging it early. Both scenarios need direct coordination with the Program Officer and Grants Management Specialist rather than being handled as if the transfer were a routine, isolated action.

How this fits the rest of post-award administration

A change of grantee institution is one of several actions that require NIH’s written prior approval before they take effect; for the full landscape of post-award prior-approval triggers — significant rebudgeting, change in scope, key-personnel changes, carryover of unobligated funds — and who at NIH has authority over each, see Resolving Post-Award Issues with NIH Grants. For the underlying concept of NIH prior approval itself, see NIH Prior Approval and the general Prior Approval definition. The account credential a signing official needs to submit a Relinquishing Statement or a PI needs to access their record in eRA Commons is the eRA Commons ID; see eRA Commons Roles for who at an institution actually holds the system access to act on a transfer. Once a project reaches its final reporting deadline — whether at the relinquishing institution’s final budget period or the receiving institution’s eventual project end — the standard closeout requirements apply; see NIH Closeout and SF-425: The Federal Financial Report Explained for what that involves.

Frequently asked questions

Does the grant number change when an NIH award transfers to a new institution?

The core grant number stays associated with the same project, but the award record reflects the change of recipient institution through NIH’s standard transfer/renewal numbering conventions, and the receiving institution’s own award identifiers apply going forward. The practical point for administrators is that the transferred award is not a brand-new competing grant — it is the same project continuing under new institutional ownership.

Who submits the paperwork first — the old institution or the new one?

The relinquishing (old) institution goes first: its Authorized Organizational Representative submits the Relinquishing Statement (PHS 3734) through eRA Commons, identifying the receiving institution and the proposed timing. The receiving institution’s Type 7 change-of-institution application follows and is evaluated once NIH has the relinquishing side’s documentation in hand.

Can NIH deny a change of grantee institution request?

Yes. Approval is not automatic, and NIH evaluates the receiving institution’s facilities, budget, and compliance documentation (including IRB/IACUC status) before approving a transfer. A request submitted with an incomplete application, unresolved compliance issues, or during a period NIH disfavors for transfers — such as an active no-cost extension without prior discussion with the Program Officer and Grants Management Specialist — can be delayed or denied.

What happens to grant-funded equipment when a PI moves institutions?

Equipment purchased with grant funds is subject to NIH’s property management standards under 2 CFR 200.313 and 200.314. In a transfer, the receiving institution’s Type 7 application must include a detailed inventory of any equipment moving with the project, and listing it in the application constitutes accepting title to it. Equipment not listed generally stays with the relinquishing institution.

Does an institutional training grant like a T32 transfer with its program director?

Generally, no. NIH awards a T-series institutional training grant to the institution to administer a training program, not to an individual program director for a specific project, so it does not follow a departing director the way an R01 follows a departing PI. The institution typically retains the award and names a new program director; how currently enrolled trainees are handled is decided with guidance from the awarding Institute or Center rather than through the standard Type 7 process.