NIH Transfer Application: Relinquishing Statement, Type 7, and Closeout

An NIH grant transfer application moves an active award from your current institution to a new one through a two-part filing: the original institution submits a relinquishing statement giving up its rights to the award, and the new institution submits a Type 7 Change of Recipient Organization application to take it over. NIH reviews both, and if it approves, issues a new Notice of Award to the receiving institution for the remainder of the project period. The grant belongs to the institution, not to you personally, so nothing moves until your current employer agrees to let it go.

When NIH Allows the Transfer

NIH Grants Policy Statement Section 8.1.2.7 requires prior approval for every change of recipient organization. A transfer is permitted when the original institution agrees to relinquish responsibility for the active project before the end of the approved project period, and the project then continues at the new institution for the remainder of that period. Funding cannot exceed the previously recommended direct costs plus applicable indirect costs at the new site.¹

A transfer can also happen when NIH has withheld a non-competing continuation award because of the current institution’s noncompliance. In that case, NIH may allow the project to move to keep the research alive. The receiving institution must be an eligible recipient of federal funds, with the administrative infrastructure, compliance systems, and facilities to manage NIH oversight. The PI must have no active findings of research misconduct or debarment.

One boundary worth knowing: if your grant is already in a no-cost extension, some NIH institutes will not approve a transfer except under extraordinary circumstances.² Each institute has discretion, so contact your grants management specialist and program officer before assuming a no-cost extension transfer is possible.

Timeline: Start Months Before You Move

The transfer request must reach NIH before your anticipated start date at the new institution, and the agency recommends submitting it several months in advance.³ Some institutes explicitly expect at least three months of lead time.² Ninety days of buffer is a sensible working assumption because three separate pieces have to come together: the relinquishing statement from the old institution, the full Type 7 application from the new institution, and NIH’s own review of both.

Before filing anything, talk to the awarding institute’s Grants Management Specialist. NIH encourages this conversation, and it can surface problems early, such as budget issues or concerns about the new research environment that could slow or derail the request.

What Your Current Institution Files: The Relinquishing Statement

The current institution starts the process by submitting a Relinquishing Statement, PHS Form 3734, filed electronically through eRA Commons by a Signing Official.⁴ The form captures the grant number, the proposed effective date of the transfer, and the estimated unexpended balance broken into direct costs and indirect costs.⁵

The proposed transfer date should align with when you officially begin at the new institution. Accuracy on the financial figures matters because the dollar amount the old institution relinquishes sets the ceiling for what the new institution can request. If NIH’s records don’t match the numbers on the form, the discrepancy causes delays or triggers a review of the project’s spending history.

The relinquishing institution must also list any equipment bought with grant funds that will move to the new location. NIH policy states that a transfer normally will be permitted only when all permanent benefits of the original grant can be transferred, including equipment purchased in whole or in part with grant funds.¹

What the New Institution Files: The Type 7 Application

The receiving institution submits a Type 7 application using the Change of Recipient Organization Parent Funding Opportunity Announcement. Most grants are submitted electronically. Paper submission via PHS 398 is an alternative when electronic filing is not possible, and multi-project and complex activity codes require paper submission.³

The application must include, at a minimum:

SF 424 (R&R) Cover Form. Put the current grant’s institute and serial number in the Federal Identifier field. Select “Revision” as the application type and mark “Other” with “Change of Recipient Organization” as the description.
R&R Other Project Information, with a description of the new facilities and their probable effect on the project, plus IRB and IACUC documentation if the research involves human subjects or animals.
A detailed equipment list. Including equipment in the new institution’s application counts as formal acceptance of title.
Updated biosketches for the PI, existing senior and key personnel, and anyone new joining the project.
An R&R Detailed Budget for the remaining project period, based on the direct costs the original institution relinquished, unless the awarding institute instructs otherwise.
A research plan statement on whether the overall aims have changed. If they have, provide updated aims; if not, include the originals.

If the transfer falls on the anniversary date of the award, the application typically includes a progress report covering work at the old institution. For mid-budget-period transfers, the awarding institute may still request a progress summary.

The application must also state whether the change in institution is related to concerns about safety or work environments, including harassment, bullying, retaliation, or hostile working conditions involving the PI.¹ This disclosure goes in the introduction section of the Type 7 application. It’s a newer requirement, and omitting it can hold up the review.

Updated Other Support documentation is required for the PI and all senior or key personnel. As of January 25, 2026, NIH mandates the use of SciENcv to generate these forms, with system enforcement beginning May 8, 2026. Forms must be created within SciENcv and attached to the application; no downloadable blank template exists.⁶ The grant being transferred should not be listed as Other Support in the application; it belongs on the cover form and in the budget.

The Indirect Cost Trap

You cannot request more direct cost funding than what was previously recommended for the remaining project period. The applicable indirect cost rate, however, will be the new institution’s negotiated rate, which may be higher or lower than your old institution’s.¹

That creates a practical squeeze. If the new institution has a significantly higher indirect cost rate, the same direct cost pool supports a larger overhead charge, and NIH generally will not award additional indirect costs beyond those calculated in the approved budget for the competitive segment.⁷ Moving to a higher-overhead institution can reduce the money available for the actual research. Talk to the awarding institute’s Grants Management Specialist about whether any adjustment is possible before you finalize the budget.

Equipment, Data, and Regulatory Approvals

Both the relinquishing statement and the Type 7 application should carry matching equipment lists. The old institution voluntarily transfers title as part of its relinquishment, and the new institution accepts title by listing the equipment in its application. If the old institution does not cooperate on equipment, NIH reserves the right to transfer title directly to the new organization.⁸³

Research data is a separate question. Under NIH policy, the recipient institution generally owns the rights in data resulting from a grant-supported project, and that ownership does not disappear when the PI leaves. NIH retains a royalty-free, nonexclusive, and irrevocable license to reproduce, publish, or otherwise use the material.⁹ NIH policy doesn’t spell out a mandatory data handover procedure, so access to lab notebooks, primary records, and proprietary biological materials is negotiated directly between the PI and the two institutions, sometimes through a Material Transfer Agreement.

If your research involves human subjects or vertebrate animals, no costs can be charged to the NIH award at the new site without valid approvals there. Human subjects work requires an active Federal Wide Assurance from OHRP and IRB approval covering the specific protocol. Animal work requires a valid Animal Welfare Assurance from OLAW and IACUC approval.¹⁰ The new institution’s IRB or IACUC conducts its own independent review, which takes time. Start those protocol submissions well before the transfer date. If approvals aren’t in hand at submission, the awarding institute may issue the new award with a restriction preventing work with human subjects or animals until the documentation is provided.³

NIH Review and the New Notice of Award

After both filings arrive, NIH weighs whether there is a continued need for the project, whether the new institution can provide an adequate research environment, and whether the transfer serves the public interest. If something about the new environment would fundamentally undermine the research, such as a missing core facility or the loss of a critical co-investigator who is not moving, NIH can deny the request.

When the review is complete and the transfer approved, NIH issues a new Notice of Award to the receiving institution. That document replaces the original award, establishing new terms including updated reporting deadlines and the confirmed funding amount. The new institution becomes the legal recipient of the federal funds and assumes all responsibility for grant management, reporting, and compliance from that point forward.¹¹

Closeout Obligations That Release the Money

The relinquishing institution still has two documents to file after the transfer:

Final Invention Statement (PHS Form 568), reporting any inventions conceived or first reduced to practice under the grant during that institution’s period of performance.
Final Federal Financial Report (FFR), due within 120 days after the end of the competitive segment and submitted electronically through the Payment Management System.¹²

The FFR deserves particular attention because its acceptance triggers the actual transfer of unexpended funds to the new institution.² A late or incomplete FFR delays the money the new institution needs to operate. If you have already moved and are waiting to spend, make sure someone at the old institution is tracking that deadline.

If Your Current Institution Won’t Release the Grant

The whole process depends on the original institution agreeing to relinquish. NIH policy states that the transfer is permitted when the original recipient “has agreed to relinquish responsibility.”¹ NIH does not have an established mechanism to force an unwilling institution to release a grant.

Your options are limited if your current employer delays or refuses. The grant legally belongs to the institution, not to you. The most productive step is to involve your NIH Program Officer early, since they can sometimes facilitate conversations between institutions. Where the institution has been found noncompliant or NIH has withheld funding, the agency has more leverage to redirect the award. In a straightforward dispute between a departing PI and an institution that wants to keep the grant, the institution holds the stronger position, and some PIs in that situation end up reapplying for new funding at the new institution rather than waiting out a stalemate.

1
National Institutes of Health. NIH Grants Policy Statement – 8.1.2 Prior Approval Requirements
2
National Institute of Arthritis and Musculoskeletal and Skin Diseases. Change of Recipient Organization (Transfers)
3
National Institutes of Health. Change of Recipient Organization (Type 7 Parent Clinical Trial Optional)
4
eRA Commons. Submit Relinquishing Statement (If Needed)
5
National Institutes of Health. Official Statement Relinquishing Interests and Rights in a Public Health Service Research Grant
6
National Institutes of Health. Current and Pending (Other) Support (CPOS) Common Form
7
National Institutes of Health. NIH Grants Policy Statement – 7.4 Reimbursement of Indirect Costs
8
eCFR. 2 CFR 200.313 – Equipment
9
National Institutes of Health. NIH Grants Policy Statement – Rights in Data (Publication and Copyrighting)
10
National Institutes of Health. NIH Grants Policy Statement – 4.1.1 Animal Welfare Requirements
11
National Institutes of Health. NIH Grants Policy Statement
12
National Institutes of Health. Federal Financial Report (FFR)