Project Changes Requiring Prior Approval and Expanded Authority From Sponsor - H08
The purpose of this procedure is to assist Principal Investigators (PI's), schools, departments, units and personnel of OHIO to effectively manage the finances of sponsored program awards by providing guidelines and procedures for attaining prior approvals when applicable. Changes to a sponsored project that require prior approval from the sponsor are to be coordinated through the Office of Research and Sponsored Programs (ORSP) and approved by ORSP.
This procedure applies to all sponsored projects subject to OU Policy 19.045 Administering External Grants and Contracts set up as separate accounts in the OHIO Financial Management System (FMS).
The Federal Demonstration Partnership (FDP) has assembled a Prior Approval Matrix that summarized the project changes requiring federal agency approval and those that can be approved and/or tracked internally under expanded authority. The ORSP staff will review each revision for the prior approval and expanded authority determination, prior to executing the transaction. If it is determined that prior approval is required, the PI may submit the request to the sponsor or authorize the ORSP staff to make the request on their behalf.
Expanded authority refers to a limited number of actions that normally require prior approval by the awarding agency but for which the agency has waived its authority and given this authority to the grantee. The Prior Approval Matrix shows “waived” where the agency does not require prior approval for the specific action.
Most sponsors understand the need for flexibility in adhering to the proposal budget and allow principal investigators (PIs) to change various line items without agency approval, provided such changes do not affect the scope of work. This means that actual expenditures in many budget categories may vary from the original proposal. However, some sponsors may place limitations on shifts into or out of certain expense categories; may not allow any single expense category to be “overdrawn” or may limit the budget changes to a certain dollar amount or percentage. Because rebudgeting is a contractual change, when prior approval from the sponsor for a budget change is needed, the request must be made through the Office of Research and Sponsored Programs (ORSP). Prior approval should generally be requested in the following instances:
If the rebudgeting will involve moving substantial sums into or out of a budget category — generally the lesser of 25% of the total direct costs or $250,000. The only exception is for NIH modular grants when the scope remains unchanged and National Science Foundation grants where the scope remains unchanged.
If the rebudgeting will result in a change in the scope of work, regardless of the dollar amount being rebudgeted.
No Cost (Time) Extension (NCTE or NCE)
If the PI believes that the project can be completed with the funds remaining, but needs more time to complete the work, they must request an official extension of the end date of the project, known as a “no-cost extension.” Many federal agencies now allow for a one-time 12-month automatic time extension, as long as notification is provided to the agency at least 10-30 days prior to the award termination date, such notifications must be submitted by ORSP. Other agencies may require a formal request for extension, which must be submitted to ORSP for review, signature and submission to the funding agency. A justification for why the project needs additional time must be provided; “spending out” the remaining funds is not an acceptable justification.
Supplemental funding requests
If, during the course of the project, the PI feels that supplemental funds will be needed in order to complete the work, he or she must submit a supplemental funding request to the agency in the form of a proposal outlining the work to be done and the additional funds required. A budget and budget narrative should be included. Any requests for supplemental funding should be submitted through Leo and require the same approvals as a standard proposal.
Substantive changes to proposed research (change in scope)
Significant changes in the research from what was originally proposed and approved always require notification and/or approval from the sponsor. PIs are advised to contact the Program Officer as soon as possible in the following situations:
Changes in Objectives or Scope
Neither the phenomena under study nor the objective(s) of the project stated in the proposal should be changed without first obtaining the sponsor’s approval. Such changes should be proposed to the sponsor in writing and countersigned by an Authorized Organizational Representative at ORSP.
Changes in Methodology
The PI may wish to pursue interesting and important leads that arise during the conduct of a project, or to adopt an alternative approach that appears to be a more promising means of achieving the objective(s) of the project. In these situations the PI should contact the Program Officer to ascertain whether formal approval is necessary.
Significant Changes, Delays or Events of Unusual Interest
It is appropriate for the PI to contact the Program Officer when he or she becomes aware of any delays or adverse conditions that may affect the ability to attain the objective(s) of the project or to meet any time schedules outlined in the original proposal. The Program Officer should also be informed when any events of unusual interest occur during the course of the project.
Change in level of PI (Co-PI, Key Personnel) effort
The sponsor’s decision to support or not to support a proposal is based to some extent on the evaluation of the PI’s knowledge of the field of study and ability to conduct the project. Therefore, sponsors expect to be notified formally if PI, Co-PI or key personnel:
- devotes substantially less effort (25% reduction) to the work than anticipated in the approved proposal;
- leaves the university, or
- otherwise relinquishes active direction of the project
A letter requesting a change in PI must be submitted through ORSP. A statement of approval from the department chair and/or the college dean must be provided to ORSP at the time of the request. All such PI change request letters should include a CV (biosketch) and a current and pending support form for the proposed new PI.
Absence of PI
If the PI will be away from the project for a period of longer than three months, arrangements for interim oversight of the project should be made and a formal request for approval sent to the sponsor. This information should be provided in writing to the Program Officer as far in advance as possible, and counter signed by ORSP. The Program Officer typically provides written approval of such arrangements. If the arrangements are not satisfactory to the sponsor, the award may be terminated.
Transfer of an award to or from Ohio University
Awards for sponsored funding are made to the institution and not directly to the PI. For this reason, when a PI wishes to transfer an award to or from the university, appropriate institutional approvals must be sought. It is the PI’s responsibility to notify the departmental administrator, ORSP, and his or her program manager as soon as possible to alert them to the need for a transfer. No transfers will be made unless the PI is up to date on all technical or progress reporting requirements.
For transfer of awards and equipment (if any) from the university to the PI’s new institution, please complete the PI Separation form located on the forms page of the ORSP website and route to the appropriate personnel for approvals. Formal relinquishment of the award to the sponsor must be in writing and signed by the university’s Authorized Organizational Representative, the Director of ORSP.
If an award and its associated equipment is to be transferred to the university, the original institution must formally relinquish the award to the sponsor and provide a final financial report. If the sponsor agrees, they will then reissue the balance of the award funding to OU. Along with the award document, the PI must provide to OU an approved budget and scope of work through the proposal routing system (Leo) and a copy of the relinquishment statement signed by an authorized official of the original institution. ORSP will not process the award for setup until all of these items are received.
When the award being relinquished has associated equipment that needs to be transferred, particular attention must be paid as to whether the equipment is vested with the institution or with the sponsor. If the equipment is vested with the sponsor or is considered “federally-owned” then sponsor approval for transferring the equipment needs to be received prior to OU acceptance. The department is responsible for working with Asset Management and ORSP to ensure proper tagging in the OHIO inventory system.
Equipment not in the original budget
For federal awards, approval is not generally necessary to request approval from the sponsor when a PI wishes to purchase an item of capital equipment (costing more than $5,000 and with a useful life of one or more years); however, if the equipment was not in the original proposal submission, prior approval may be required. Please check or your award document to verify agency requirements.
Nonfederal awards may be more restrictive, and it is best to confirm whether formal approvals are needed with the agency’s contracting officer. Any such formal approval requests must be counter-signed by an Authorized Organizational Representative at ORSP prior to submission.
Subcontracts not in the original budget
In most cases sponsors must approve subcontracts not identified in the original proposal. Appropriate documentation from the subcontractor must be provided in order for ORSP to submit the request for agency approval. This documentation includes:
- Letter of support from an authorized official of the subcontractor
- Statement of work
- Budget and budget justification for the subcontractor's portion of the work
- Revised budget for the OU portion of the work
- Cover letter from the PI explaining the need for the subcontract and how the OU scope of work is changing to accommodate the subcontract
Training is available through ORSP upon request. Submit request for training to ORSP@ohio.edu.
ROLES AND RESPONSIBILITIES