Changes Requiring Internal and Sponsor 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 project award and the Sponsor's specific policies for that type of award.
Federal Demonstration Partnership (FDP)
In 1986, five federal agencies began a demonstration project to eliminate unnecessary administrative burdens on sponsored project awards. The result of the project was an implementation of "expanded authorities" for selected institutions.
Our participation in the Federal Demonstration Partnership has reduced the number of situations demanding prior approval from the sponsoring institutions. The primary objective of the Federal Demonstration Partnership is to allow PI’s to focus on research as opposed to administrative duties. Under the terms and conditions of the Federal Demonstration Partnership, the Office of Sponsored Projects can internally approve many changes that previously required the prior approval of the Sponsor, these internal approvals include:
90 Day Pre Award Costs
First No-Cost Extension Request
It should be noted that not all Federal sponsored project awards are covered by the terms of the Federal Demonstration Partnership. Neither the National Endowment for the Humanities (NEH) nor the National Endowment for the Arts (NEA) participates in the Federal Demonstration Partnership.
Most federal agencies will clearly state in the Notice of Award if the terms and conditions of the "Federal Demonstration Partnership" apply to that award. Additionally, each federal agency has exceptions to the general Federal Demonstration Partnership terms and conditions that may have additional requirements.
General Terms and Conditions of the Federal Demonstration Partnership
Allowable Costs and Prior Approvals: Costs charged to a sponsored project award under the Federal Demonstration Partnership must meet the same standards as all other Federal sponsored project awards for allowability, allocability and reasonableness. The allowability of costs shall be determined in accordance with the requirements of the award and the applicable Federal Cost Principles. Please contact the Office of Sponsored Projects for questions on the allowability of a specific cost.
Project Relatedness: When the same person serves as the Principal Investigator on two or more Federal awards or when two or more awards with different Principal Investigators involve interrelated theoretical approaches or study the same phenomena, the Principal Investigators 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. Please contact the Office of Sponsored Projects for additional information on the procedure for establishing "relatedness."
Changes in Objectives or Scope: Prior approval of the awarding agency is required for any changes in the study or changes in the objectives of that project. Actions that may be considered a change of scope include substitution of one animal model for another, any change from the approved use of animals or human subjects, applying new technology, transferring the performance of substantive programmatic work to a third party and change of key personnel whose expertise is critical to the approved project.
Absence or Change of Principal Investigator: Prior approval of the awarding agency is required for any absence of the Principal Investigator for generally a period of 3 months or more. A substitute Principal Investigator may be named, or the award might be relinquished depending on the circumstances.
Preaward Costs: The Office of Sponsored Projects has the authority to approve preaward costs of up to 90 days prior to the effective date of an award. Please submit the Advance Account Request to the Office of Sponsored Projects when requesting to charge preaward costs. If there are preaward expenses that go beyond 90 days, the Principal Investigator will need to get prior approval from the sponsor.
Extensions without Additional Funds: Upon request from the Principal Investigator and at least 30 days prior to the end date, the Office of Sponsored Projects can extend the expiration date of the sponsored project award for a period of up to 12 months. A sponsored project award may be extended only one time by the Office of Sponsored Projects. Additional extensions would need prior approval from the sponsor. Departments will need to send a No-Cost Extension Request to their Sponsored Research Manager when the sponsored project award is made under the terms and conditions of the Federal Demonstration Partnership and it is the first no-cost extension request. All additional no-cost extension requests would require prior approval from the awarding agency.
Equipment: The principal investigator may approve the acquisition of equipment not listed in the approved sponsored project award budget. Any items over $25,000 may require the prior approval of the awarding agency. For items that don't require prior approval by the awarding agency, please send an email specifying the amounts to be rebudgeted to your Sponsored Research Manager. In addition, any "excess" Facilities and Administration Cost generated by the rebudgeting may be rebudgeted to direct cost categories. For items over $25,000, please contact your Sponsored Research Manager to find out if prior approval is needed by the sponsor. No equipment can be purchased during the last six months on a sponsored project award.
Foreign Travel: Prior approval from the sponsor may be required for foreign travel. Foreign travel always needs to directly benefit the sponsored project award. All travel must occur on U.S. Flag Air Carriers unless such service is unavailable.
Unobligated Balances/Carryover Funds (if awarded under FDP): The Office of Sponsored Projects will automatically carryover any unobligated balance remaining at the end of the current budget period. The Office of Sponsored Projects shall notify the awarding agency by means of the required Financial Report. The ability to carryover any unexpended balance at the end of a competitive segment depends on the agency guidelines.
FEDERAL SPONSORED PROJECT AWARDS NOT COVERED BY THE FDP
1. Public Health Service (SAMSHA, CDC, HRSA)
The following actions require prior approval of the agency for Public Health Services Awards not covered by the Federal Demonstration Partnership:
•Change of Scope
•Change of Principal Investigator
•Change of Grantee Institution/Successor in Interest/Recipient Institution Name
•Transferring Substantive Programmatic Work (Subawards)
•Carryover of Unobligated Funds from One Budget Period to Another within an Approved Project Period
•Extensions of the Budget/Project Period with or Without Additional Funds
•Equipment exceeding $25,000 per unit
•Alternative Use of Salary Support Due to Receipt of a Research Care Development Award
•Alterations and Renovations Projects over $25,000
•Audiovisual Materials Exceeding $25,000
•Transferring Amounts from Trainee Costs*
•Capital Expenditures for land or buildings
•Patient Care Costs
•Publication and Printing Costs Exceeding $25,000 for a Single Publication
•Consumer/Provider Board Participation
•Need for Additional Funds
•Closely Related Work/Project Relatedness
•Indemnification against Third Parties
•Transfer of Funds between Construction and Non-Construction
•Program Income/Sponsored project award-Related Income
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 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 allow rebudgeting without prior approval. However significant changes to the budget almost always require prior approval by the sponsor. PI and OSP will need to sign the request letter, OSP sends the fully signed letter to the sponsor for their approval.
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 project 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 by the sponsor. Department Grant Manager's/Principal Investigator must notify OSP of absence of Principal Investigator "prior" to absence. PI and OSP need to sign request letter that OSP will send to the sponsor for prior approval.
Salary charges to sponsored project 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.
The principal investigator may usually approve the acquisition of items of equipment not listed in the approved sponsored project award budget. Any items over $5,000 may require the prior approval of the awarding agency, check with your Sponsored Research Manager to verify. The Office of Sponsored Projects approves any capital equipment on a grant that is $5,000 or more. No equipment can be purchased during the last 6 months on a grant or contract.
A sponsor's terms and conditions must be followed with regard to foreign travel. Some sponsors require prior approval for foreign travel, even when the foreign travel has been included in the initially approved budget. Request letters should be signed by both the PI and the Office of Sponsored Projects who will send the fully signed letter request 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 Manager needs to submit a formal letter signed by the PI requesting to carryover funds to their Sponsored Research Manager, after OSP signs the letter request, they send the fully signed request letter to the sponsor for prior approval.
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. A request letter needs to be signed by both the PI and OSP before OSP sends the request letter to the sponsor for prior approval.
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 as internal documentation.