Prior Approvals
Circular OMB A-110 establishes the approved project budget as the financial framework for federal award projects, and sponsors may evaluate the project against the budget at any time. While sponsors may allow certain flexibilities, RU and sponsors require expenditures and efforts on awards to remain consistent with the approved project scope and budget throughout the award's lifetime.
Sponsors may question or disallow changes in expenditures and research activities that appear inconsistent with the funded project scope and budget. PIs are normally obligated to request prior approval when budget and programmatic revisions indicate a significant change in project scope.
For NIH prior approval requirements refer to the NIH Grants Policy Statement (Exhibit 7: Summary of Actions Requiring NIH Prior Approval).
Selected Prior Approval Requirements
All federal grants require advanced written approval by the assigned sponsor’s grant officer (who will coordinate with the program officer) for:
- Change in PI
- PI’s absence from the project for more than three months
- Change in project scope.
- Reduction in PI/key personnel level of effort by 25 percent or more.
Some federal agencies delegate authority for re-budgeting, pre-award costs, no-cost extensions (NCEs), etc. Details can be found in this National Science Foundation Prior Approval Matrix (PDF).
In addition, specific funding programs may include their own prior approval conditions and following them is a requirement.
All prior approval requests should be written and justified by the PI and endorsed and submitted by OSPA as the Institutional Authorized Representative.
OSPA's Tips Related to Prior Approvals
[February 14, 2013] What is the Federal policy regarding significant effort reductions on an active research grant?
