Change request (project)

A change request is the formal mechanism a recipient uses to ask a sponsor’s permission to amend something about an already-approved project — scope, key personnel, budget allocation, subawards, or timeline. Whether one is required at all turns on a specific, largely enumerated question: does the change fall on the sponsor’s list of items requiring prior written approval?

The prior-approval trigger list

For US federal awards, 2 CFR 200.308(f) lists the specific actions that require prior approval regardless of the award’s general rebudgeting threshold: a change in the scope or objective of the project, even without any budget change; a change in key personnel named or identified by position in the award; a PD/PI’s disengagement from the project for more than three months, or a 25 percent reduction in their committed time and effort; redirecting participant support costs to other budget categories; new subaward activities not proposed or approved in the original award; a change in the total approved cost-sharing amount; the need for additional federal funds; transfers between construction and non-construction categories; and any extension beyond an already-authorized one-time no-cost extension. The absence of prior approval does not, by itself, affect whether a cost is reasonable or allocable — unless prior approval was specifically required for that item.

What does not need one

A routine purchase that stays within an approved budget category, or a minor methodological refinement that stays inside the project’s originally approved aims, does not trigger a change request — these are exactly the kinds of adjustment researchers make constantly without sponsor sign-off.

How it’s submitted

NIH prior-approval requests are typically submitted through the eRA Commons Prior Approval Module; Horizon Europe changes go through a formal amendment request processed via the Funding & Tenders Portal.

What follows approval

An approved change request results in an updated project plan that documents the change going forward — the request itself is the ask; the updated plan is the record of what was granted.

vs. project pivot

A project pivot is the underlying scientific or methodological decision; a change request is the formal compliance mechanism triggered once that decision rises to the level the sponsor’s prior-approval list requires.