Prior Approval and Expanded Authority

After an award is made, changes resulting from circumstances not anticipated in the planning stages of the project are sometimes necessary. These changes can be programmatic or financial in nature. Some changes require the sponsor’s prior written approval, others may be authorized internally by OSP. See below for examples and refer to the sponsor’s regulations and award documents. Contact your OSP Post-Award Team member with specific questions. Requests to sponsors must be authorized by OSP prior to submission to the sponsor.

Examples of changes during the lifecycle of an award

• Changes in scope of work (SOW)
• Change of Principal Investigator or significant reduction of effort
• Changes/additions to collaborating institutions/subcontractors responsible for carrying out a portion of the SOW
• No cost extension of the budget or project period (extension of time without additional funds)
• Re-budgeting
• For federal awards, the Uniform Guidance grants permission to an awardee to re-budget, except when there is a change in the SOW or the need for additional funding
• Non-federal awards may provide different thresholds for re-budgeting, by percentage or amount of deviation by budget category or line item, or stipulate that “substantial” deviation requires prior approval
• Carry-forward of funds from one budget period into the next within a project period

Expanded Authorities

There are a limited number of post-award actions that normally require prior sponsor approval for which approval authorities have been ‘expanded’ to the grantee. These actions are commonly referred to as ‘Expanded Authorities’ and are for changes necessary for the completion of the project within the original scope of work and budget and generally apply to Federal research assistance awards (i.e., grants and cooperative agreements) and not contracts.

Under Expanded Authorities, sponsoring agencies may waive certain prior approval requirements and provide authority for a recipient to undertake activities and expenditures without prior approval.

Areas in which federal awarding agencies have the option to waive prior approvals are outlined in Uniform Guidance (2 CFR § 200.308(d)), such as:

• A one-time extension of a period of performance (i.e., No-Cost Extension)
• Transfer of funds among direct cost categories (unless the transfer results in a change of the scope of work or impacts trainee costs). Rebudgeting authority is general limited to 10% of the total approval budget

Prior Approval Matrix

Not all agencies exercise their right to waive prior approvals. For those agencies that have, they may not waive all of the prior approvals and they may not waive them for every program. Therefore, it is important to check the agency’s policies as well as specific program terms and conditions to see if these authorities have been granted. If an agency/program grants expanded authorities, they are automatically applied unless overridden in the NOA. When in doubt, begin with the award terms and conditions, working back to program and agency-specific terms.

For a comprehensive list of actions needing prior written approval by the agency, refer to the Research Term and Condition (RTC) Prior Approval Matrix as a quick resource to determine when sponsor prior approval is required for certain actions. The RTC Prior Approval Matrix is only applicable to those awards that incorporate the RTC into their terms. These are generally Grants issued by: