Prior Approval

During the life of a federally funded grant award, it may become necessary to modify certain aspects of the original award.

Some Federal sponsoring agencies, under what is frequently termed the “expanded authorities,” have delegated approval rights to the awardee for some of these modifications. The PI may request internal approval from the Controller for any of the following:

  • Pre-Award Costs - Pre-award costs incurred within the ninety (90) calendar day period immediately preceding the effective date of the award. Pre-award costs must be necessary for the effective conduct of the project and must be in accordance with the budget as proposed. Pre-award expenditures are made at the awardee’s risk. Awardee authority to approve pre-award costs does not impose an obligation on the sponsor.
  • Extension of Award Expiration Date - To initiate a one-time extension of the award expiration date of up to 12 months, funding agency must be notified at least ten days prior to original termination date. This extension may not be exercised merely for the purpose of using any unobligated balance. Extensions past the initial 12 months require prior-approval from the funding agency (funding agency must be notified at least 45 days prior to original termination date).
  • Revision of Budget - The budget plan is the financial expression of the project or program as approved during the award process. During the performance of a project, it may be appropriate for funds to be reallocated to support advancement of the project. NSF and OMB -110 authorize the transfer of funds among various budget categories for allowable expenditures without prior approval. Principal Investigators are required to remain within 25% of the proposed budget categories. When expenditures for a particular budget category are going to exceed the 25% threshold, a Budget Revision Form should be submitted with a justification that supports the advancement of the project.

Prior Approval Requirements

Awardees are required to report deviations from budget and program plans, and request prior approvals for the following changes:
  1. Change in the scope or the objective of the project.
  2. Change in PI or Co-PI.
  3. The absence for more than three months, or a 25 percent reduction in time devoted to the project, by the principal investigator.
  4. The need for additional Federal funding.
  5. The transfer of amounts budgeted for indirect costs to absorb increases in direct costs, or vice versa, if approval is required by the Federal awarding agency.
  6. The transfer of funds allotted for participant support (direct payment to trainees) to other categories of expense.
  7. Unless described in the application and funded in the approved awards, the subaward, transfer or contracting out of any work under an award. This provision does not apply to the purchase of supplies, material, equipment or general support services.

No other prior approval requirements for specific items may be imposed unless a deviation has been approved by OMB.