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Requirements
for Prior Approvals
See related discussion of reporting requirements in Chapter
5 of the ORPA Manual.
Ongoing communication between the PI and the sponsor is
a critical component of sound fiscal management. Such
conditions as rebudgeting requests, no-cost extensions,
or considerations related to the scope of the project
warrant communication in writing, with a copy retained
in the project file. Please remember that all requests
to a sponsor should be coordinated through ORPA.
In additions, regulations applicable to different types
of projects REQUIRE written notification or prior approvals
in the following situations.
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FOR
FEDERAL GRANTS: Changes in PI Status
OMB
Circular A-110
requires prior written approval from the sponsor for either
of the following circumstances involving the Principal
Investigator or approved Project Director:
- A
reduction in time devoted to the project of 25%
or more from the proposed and awarded level
- An
absence from the project for more than three months.
For
example, if your project is awarded with a commitment
of 50% of your effort, and you decide to reduce that to
30%, that reduction is more than 25% from the awarded
level and would require advance notification and approval.
If, in the original award, UR had committed to fund some
of this effort as cost sharing, the Office of Research
and Project Administration (ORPA) will also negotiate
reductions in levels of the cost-shared component of effort,
as appropriate.
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In
addition, when a PI's faculty appointment will terminate
prior to or during a project's period of performance,
the sponsor is so informed by ORPA.
Circular A-110 also requires prior approvals from the
sponsor in the following circumstances:
- change
in the scope or the objective of the project or program
(even if there is no associated budget revision)
- change
in a key person specified in the application or award
document
- need
for additional Federal funding
- transfer
of funds allotted for training allowances (direct
payment to trainees) to other categories of expense.
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FOR
FEDERAL CONTRACTS: Limitation of Funds/Limitation of Cost
clauses
In the case of federal cost-type contracts (as opposed
to grants), PIs must comply with the Limitation of Funds
and/or Limitation of Cost clauses which include the requirements
that:
- the
Contractor notify the sponsoring agency in writing
at any time that there is reason to believe the total
cost to the Government for the performance of the
project will be greater or substantially less than
the estimated cost, and further,
- the
Contractor notify the sponsoring agency if, at any
time, there is reason to believe that the costs which
are expected to be incurred in the next succeeding
60 days, when added to all costs previously incurred,
will exceed 75% of the specified estimated cost.
Failure to provide such notice may preclude UR from receiving
additional funding on that contract.
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These
notifications are intended to allow sufficient time to
arrange for and process additional funds, or for the reduction
in spending and effort in order to phase out the program
in an orderly fashion if additional funds are not available.
The Principal Investigator's Department Chair and School
Dean should also be informed, in advance, of potential
funding problems.
In the case of grants, similar restrictions often apply
and appear in the grant award itself or in the accompanying
agency policy manual or administrative guide. Check
the terms of your particular award.
In all cases, notifications of contract or grant status,
including those described above, must be made in writing
to the administrative official in the sponsoring agency.
Such notifications must be coordinated through ORPA.
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