Prior Approvals for Post Award Grant Actions SOP

This standard operating procedure (SOP) includes the following sections: Purpose, Procedure, Contacts, and Links.


To change a funded project in a way that requires prior approval from NIAID.


While principal investigators (PIs) can perform a range of grant actions under the NIH standard terms of award, they must get prior approval from NIAID for the following things:

  • Change in scope. Get details at Changes to Project or Budget.
    • Prior approval is not required for charging preaward costs before the start date of a noncompeting grant (the grant resulting from your progress report).
    • Keep in mind that incurring preaward costs does not obligate NIH to make the award or provide budget increases.
  • Transfer of a grant from one institution to another.
  • Change of recipient institution, for example
    • Change in institution name
    • Merger
  • Change of PI, change from a single PI to a multiple PI award, or removal of PIs from a multiple PI award. See the Change of Principal Investigator SOP.
  • Change in key personnel listed on the Notice of Award.
  • Reduction of PI effort by 25 percent or more. 
  • Change in PI status, e.g., restrictions on access to institution’s resources.
  • Addition of a new foreign site, foreign subaward, or foreign collaboration.
  • Revisions to an approved Data Management and Sharing Plan.
  • Deviation from terms of award or restrictions reflected on the Notice of Award.
  • Carryover of unobligated balances if not authorized on the Notice of Award.
  • Late no-cost extension requests or requests beyond 12 months after the end of the grant period. For more information, read the No-Cost Extension SOP.
  • Alterations and renovations:
    • Rebudgeting more than 25 percent of a budget period's total approved budget into alterations and renovations costs.
    • Any alterations and renovations project exceeding $500,000.
    • Major alterations and renovations costs for any foreign grant.
  • Rebudgeting of funds from trainee costs to other budget categories.
  • Rebudgeting of salary and fringe benefits for investigators who receive career development awards.
  • Capital expenditures (construction or acquisition of land or building).
  • Transfer of funds between construction and non-construction work.
  • Prior approval is required for subawards based on fixed amounts when:
    • New fixed amount subawards are added to grants.
    • Competing applications do not identify plans to issue fixed amount subawards and subsequently request approval.
    • Previously existing fixed amount subawards are substantially modified resulting in a change in scope.

Read more about prior-approval requirements in section 8.1 Changes in Project and Budget in the NIH Grants Policy Statement.

Principal Investigators

  • For all requests, get your institutional business official to send prior approval requests to your grants management specialist, with a copy to your program officer, within 30 days of the planned use of funds.
    • Make sure the request includes the following information:
      • Grant number in the subject line
      • Your name, title, organization, telephone and fax number, and email address
      • Authorized business official’s name and title, telephone and fax number, and email address
      • Justification for the proposed change
    • You don't sign letters, but you must have a signature assurance on file.
    • If you spend grant funds or make any of the changes above without written approval, NIAID may audit your institution, terminate your award, or disallow some costs.
  • For changes in scope, use the NIH Template to document your revised Abstract, Specific Aims, and Public Health Relevance after discussing with your program officer.
  • For mergers, acquisitions, and other successor-in-interest actions, have your institution respond to the Successor-in-Interest (Type 6 Parent) announcement.
  • To transfer a grant to another institution*, ensure the following occurs at least 2 months before you move:
    • Your new institution responds to the Change of Recipient Organization (Type 7 Parent Clinical Trial Optional) announcement.
    • Your institutional business official submits a relinquishing statement using the Change of Institution module in the eRA Commons.

      * Keep in mind that NIAID will not consider or approve the transfer of a grant in a no-cost extension, except under an extraordinary circumstance. If you believe you have an extraordinary circumstance NIAID should consider, contact both your assigned grants management specialist and program officer prior to requesting a transfer of a grant in a no-cost extension. NIAID generally does not transfer multiproject grants due to the complexity and potential disruption to synergy amongst the Cores and Projects. 

Grants Management Specialists

  • Do the following within 5 to 7 working days of receiving a request:
    • Confirm receipt of the request by sending a Prior Approval Request—Initial Response email to the recipient.
  • You have up to 30 days to review the following:
    • Determine if the proposed change is allowed 
    • Seek guidance from the appropriate division coordinator when required (e.g., if disapproving a request)
    • Receive comments and concurrence from program staff, followed by approval or disapproval from GMP staff
  • If GMP staff
    • Approves a request, send notification by email to the PI and institutional business official. A revised Notice of Award will be issued, if required by GMP.
    • Does not approve a request, email the PI a Disapproval Letter.
  • Upload all correspondence and GMP staff approval and disapproval letter into eAdditions.

Program Officers

  • Provide advice to grants management specialists on prior approval requests.
  • Provide comments and concurrence for the official file.


Recipients with questions should contact the program officer or grants management specialist listed in the eRA Commons. For more information, read Contacting Program Officers and Grants Management Specialists.

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