Changes in Scope of Project

Guidelines for Post Award Prior Approval

Changes in Project

There may be changes or alteration in a sponsored project which was approved by the agency.  These changes may relate to finances, personnel, or timing of the project.  Generally, the agency requires prior approval for these changes; the minimal requirements for agency prior approval are contained in Circular A-110, Subpart C – Post-award Requirements: Financial and Program Management, Section 25.  Therefore, it is important that you obtain prior approval from OSP and Institution by completing the Prior Approval Form.  The instructions for completing and submitting the form are contained in the form.

Budget Circular A-110, published by the Office of Management and Budget (OMB), provides standardized government-wide administrative regulations for post-award approvals.  While granting institutions more flexibility in managing these approvals, there are items that need prior approval from the agency.

All requests for prior approval must be in writing, well-justified, and accompanied by supporting documentation to ensure that changes are reasonable and appropriate.  The written requests have to be submitted to OSP, to be reviewed, processed and submitted. 

The following guidelines have been developed by OSP to assist the PI in writing requests for changes in federally funded projects:

Items requiring Institutional Prior Approval

  • Purchase of equipment to be used solely for the project, which was not identified in the original budget that was part of the proposal
  • Requests for travel exceeding the original amount
  • Pre-award costs for essential expenditures to be incurred within 90 days prior to the effective date for a new award, such as hiring of personnel and supplies.  Examples: Project director, (other than faculty/staff member who was responsible for submitting proposal), secretary and other clerical staff needed for start-up.
  • Requests for one-time no-cost extension of a year, provided that the extension is not for liquidating grant balances

Items requiring Federal Agency Prior Approval

  • Change in objectives or scope of project
  • Need for additional funding
  • Change in PI and/or key personnel ( project director, co-PI’s)
  • The absence of PI for more than three months (consecutive) or reduction of PI time (25% or more) in time devoted to project
  • Transfer of funds from one category to the other (training allowances)
  • Budgeting of pre-award costs to be incurred more than 90 days prior to the award
  • Re-budgeting for direct cost categories, where the agency share of the cost is more than $100,000, and the total amount of such transfers is 10% of the total budget approved by the agency.

 Approval must be obtained before changes are implemented.  If you do not obtain prior approvals for costs already incurred, revisions will not be reviewed by OSP and will not be submitted for agency approval.  Consult OSP before submitting Prior Approval form provided for your convenience.

 Instructions for Completing Prior Approval Form

 The PI should download and complete the Prior Approval Form and obtain the signature(s) of Dean/and or Department Chair, before submitting the form to OSP.  OSP will review the form and the accompanying justification for the revisions and will submit requests to the agency/institution.  Please remember that each request (per item) must include a detailed justification (provided form) explaining the reason for the change from the original budget or project.

In reviewing the requests, OSP will check for compliance with regulations, policies, and procedures of the project and the objectives originally laid out in the project proposal.

Once the requests are approved, OSP will inform PI of the approval.  If items are cost-related, they will be reflected in the accounting system maintained by the Business Department for the project.

Making a Request to the Federal Agency

 Revisions requiring approval from the agency should be described in a letter from PI to the appropriate agency official.  The letter must be countersigned by the OSP, who will first review the letter and then submit the letter to the agency. 

Note:  PI’s should refer to specific grant conditions from the agency that may have been attached to the initial award letter.  Please make special note of budget restrictions and changes.  OSP will assist you if necessary.