Award Management - Prior Approvals
Although many sponsored awards allow flexibility in areas such as rebudgeting, carryforward of unobligated balances from year to year, and pre-award costs, sponsors expect expenditures to be reasonably consistent with the proposed scope of work and budget. Many federal agencies have chosen to delegate authority to the University for rebudgeting, pre-award costs, single no-cost extensions, etc. The Department and PI should refer to the sponsored award terms to determine the authorizations that apply to each award.
Sponsors often require PIs to request prior approval for significant changes that affect the scope of work and budget. Please remember that all requests to a sponsor should be coordinated through ORPA.
PI Transfer/Absence/Reduction of Effort
Advanced written sponsor approval is required when a PI intends to transfer to another institution, plans to be absent from the project for three months or more, or reduce his or her level of effort by 25% or more from the awarded level.
Circular A-110 and 2 CFR 200 Uniform Guidance also require 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.
Certain sponsor awards may not allow automatic carryforward of unexpended funds for each budget period. The Department and PI must review the sponsored award terms closely to ensure whether the award requires advanced sponsor approval for carryforward of unexpended funds to the next budget period.
ORPA has the authority to approve a first no-cost extension on most federal grants, including NIH. For audit purposes though, the PI must email their ORPA RA with a scientific justification for the extension. A no-cost extension can be requested and processed if:
- Additional time beyond the established expiration date is required to ensure adequate completion of the originally approved project.
- Continuity of grant support is required while a competing continuation application is under review.
- The extension is necessary to permit an orderly phase-out of a project that will not receive continued support.
The fact that funds remain at the expiration of the grant is not, in itself, sufficient justification for an extension without additional funds.
• In addition, the email should clearly note if a 6, 9 or 12 months no-cost extension is needed. If the grant involves human subject research and/or animals, the ORPA RA will need current IRB or IACUC approvals before they can process the extension.
• And finally, the email should also clarify the proposed effort to be devoted during the no-cost extension period of all key personnel named on the sponsor's Notice of Award (the PI is always key but sometimes, the Sponsor identifies other investigators as key). Unless we notify the sponsor otherwise, it is assumed that effort will remain the same during that period. If effort will be significantly reduced (i.e. a reduction of 25% or more from what was originally approved), we will need to request approval for the reduction in effort from the sponsor at least 30 days prior to the end date.
If effort will not be significantly reduced, the department will need to determine if sufficient funds remain in the GR FAO to cover that effort during the whole no-cost period. If insufficient funds remain, an internal cost-sharing form will need to be completed and sent to the ORPA RA.
• The request for the extension should be provided to the ORPA RA at least 20 business days prior to the projected end date.
For second no-cost extensions, prior approval from sponsor is always required. Contact your ORPA RA for additional guidance on second no-cost extension requests.