Project Changes
During the life of a sponsored award, it may become necessary to modify certain aspects of the award. Changes may involve rebudgeting of funds among budget categories or adjusting the length of a project period (e.g., requesting an extension). The award terms and conditions and related sponsor policy will dictate the amount of flexibility awardees have in making changes and the process for securing prior approval from the sponsor when required.
Many federal agencies have transferred the authority to approve certain changes on grant awards to awardee institutions. Awards issued with the Research Terms and Conditions provide "expanded authorities" to institutions. These authorities are summarized in the Research Terms and Conditions Prior Approval Matrix.
Changes Requiring Prior Approval from the Sponsor
The Principal Investigator of a federally sponsored project is typically required to report deviations from budget and program plans, and request prior approvals from the authorized representative of federal awarding agencies for the following reasons:
Change in the scope or the objective of the project or program
Change in the Principal Investigator
Absence for more than three months or a 25% reduction in time devoted to the project by the approved PI
Additional federal funding
Transfer of funds allotted for training or participant support expense (direct payment to trainees - stipend, tuition, fees) to other categories of expense
Subawards, transfers, or subcontracting out of a substantive programmatic portion of work, unless described in the application and funded in the approved award
Every award can have its own unique set of terms and conditions, so it is important to always refer to the award document when determining what changes require prior approval. While the list above is common to federal grants and cooperative agreements, they may also apply to other types of funding; however, other types of sponsors are frequently more restrictive in the level of flexibility they provide to the recipient. Contracts are typically the most restrictive.
Rebudgeting
The terms and conditions of the award may require the recipient to request the sponsor's prior approval before shifting funds from one budget category to another. Other awards may require the sponsor's prior authorization of certain types of expenditures. Many federal and industrial projects provide the Principal Investigator with broad latitude to re-budget funds as necessary to meet program objectives. Refer to the terms of the award for rebudgeting restrictions and prior approval requirements.
No-Cost Extensions (NCEs)
Most sponsoring agencies will allow an extension of the grant expiration date if more time is required to assure adequate completion of the original project scope. Although the requirements to apply for a no-cost extension (NCE) vary by sponsor, under expanded authority many federal agencies allow PSU to approve a one-time 12-month NCE to grants and some cooperative agreements. In these instances, PSU must notify the federal sponsor of our intent to exercise our authority to extend the period of performance.
When sponsor approval is required, PSU must have written confirmation of sponsor approval. This typically takes the form of a modification to the award letter or agreement.