Skip to main content

Changes Requiring Prior Approval

Principal Investigator's often want to make changes to the budget, which deviates from the proposal that was approved by the Sponsor. In some cases, it is necessary to request the prior approval of the Sponsor. In other instances, "internal", prior approval by the Office of Sponsored Projects is sufficient. The level at which approval may be granted depends upon the type of sponsored research award and the Sponsor's specific policies for that type of award. For simplicity, this manual will delineate the types of sponsored research awards as either Federal Sponsored Research Awards (e.g. National Institutes of Health, Department of Defense) or Non-Federal Sponsored Research Awards (e.g. State of New Hampshire, Private Foundations such as American Heart Association, Cystic Fibrosis Foundation, etc.). This manual is intended as a general reference. Please contact the Office of Sponsored Projects, if you have any specific questions or need assistance in contacting the sponsor.

Procedure for Initiating Changes Requiring Prior Approval

When prior approval is required by the Sponsor, such requests should be in writing, addressed to sponsor and in advance of the change. Requests for retroactive approval should be avoided. In addition, all requests should be signed by the Principal Investigator and countersigned by an authorized official from the Office of Sponsored Projects.

Rebudgeting

Rebudgeting is the process by which the Principal Investigator produces a new revised plan for spending the awarded funds. New budgets may be necessitated by such events as a change in project scope, need for supplemental funding, or the inability to raise matching funds. Most sponsors place restrictions on budget revisions, including moving funds from one category to another. Significant changes to the budget almost always require prior approval by the sponsor.

Project Relatedness

When the same person serves as principal investigator on two or more Federal awards, or when two or more awards with different principal investigator's involve interrelated theoretical approaches or study the same phenomena, the principal investigator's may request that "relatedness" be established. If two or more awards are determined to be "related" then they may be treated as a program for purposes of allocating costs. A cost that is allocable to the program may be charged to any one of the awards that make up the program, in any proportion. To establish "relatedness," a written request must be sent to the federal sponsors funding the projects involved.

Change of Scope/Salary Allocation

In general, most Sponsors require that they be informed of any changes that may effect the scope of the actual research to be performed such as an absence/change of the Principal Investigator, change of grantee institution, a change in the approved use of animals or human subjects, or a change in the objective or emphasis of the study. Usually, a significant change (decrease) in the percentage effort devoted by the key project personnel to the project is considered as affecting the scope of the research. Since the Labor Verification Reports provide the documentation of salary allocation devoted to sponsored research awards, it is important that they reflect the effort planned in the approved budget.

Absence or Change of Key Personnel

The prior approval of the awarding agency is required for any absence of the Principal Investigator for a period of 3 months or more. A substitute Principal Investigator may be named or the award will be relinquished. Changes of key personnel whose expertise is critical to the approved project must also have prior approval. Department Administrator/Principal Investigator must notify OSP of absence of Principal Investigator "prior" to absence.

Indirect Cost Rate Adjustments

The Principal Investigator is required to notify OSP if the work on the project is performed off campus for a continuous period of 3 months or more in order to receive a reduction in the approved indirect cost rate.

Extra Compensation

Salary charges to sponsored research awards are allowable at the approved College base salary rate. Extra compensation over and above the approved base salary rate is not generally approved except under unusual circumstances, such as consultation across departmental lines or is performed at a remote location and the work performed is in addition to regular departmental responsibilities. Such consulting arrangements must be specifically provided for in the award agreement and are approved in writing by the sponsor and appropriate dean.

Equipment

The principal investigator may usually approve the acquisition of items of equipment not listed in the approved sponsored research award budget, provided the cost of each item is less than $5,000. Any items over $5,000 necessitate the prior approval of the awarding agency or OSP. Unplanned purchase of equipment under $5,000 not requiring prior sponsor approval, are handled by OSP Sponsored Research Manager. The Principal Investigator must submit a brief memo stating the cost of the new equipment. No equipment can be purchased during the last 6 months on a grant or contract.

Foreign Travel

A sponsor's terms and conditions must be followed with regard to foreign travel. Many sponsors require prior approval for foreign travel, even when the foreign travel has been included in the initially approved budget. Requests should be submitted with detailed justification to the OSP, Grant Manager and will be forwarded to the sponsor. Requests for foreign travel should be made PRIOR to taking the trip and at least 30 days in advance. Note: some sponsors require up to 90 days prior notice.

Unobligated Balances/Carryover Funds

When a sponsor requires prior approval to carryover funds from one budget period to another, the Department Grant Administrator needs to submit a formal letter requesting to carryover funds to OSP, the letter needs to be signed by the Principal Investigator and then OSP.

Stipends and Tuition Remission

Any changes in the proposed stipend and/or in tuition remission requires written prior approval by the sponsor. Requests for changes must be submitted to the OSP with justification and approval of the appropriate dean.

Subawards

Subawards that were not included in the proposal require the sponsor's approval prior to executing a formal agreement and commencing work. The choice of a particular Subaward must be documented with regard to the subrecipient's qualifications to perform the work and the award's need for such services.

If "internal" approval is sufficient, a brief memo, signed by the Principal Investigator only, should be sent to the Office of Sponsored Projects to be kept with the award file as internal documentation.

Last Updated: 12/17/10