During the life of a sponsored project, it may become necessary to modify certain aspects of the original award. Such changes may involve rebudgeting of funds among expense classes or adjusting the length of a project period. Many federal agencies have transferred the authority to approve such changes to awardee institutions.

Background

Several years ago, the Federal Government streamlined the administration of sponsored research through issuance of two Office of Management and Budget (OMB) Circulars: A-21, "Cost Principles for Institutions of Higher Education"; and A-110, "Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Institutions."

These Circulars have provided more flexibility to institutions in the administration of grants. Federal agencies are authorized, at their option, to waive administrative prior written approvals required by OMB Circular A-110 and OMB Circular A-21.

In looking at the hierarchy of regulations, university policy must always be followed. A hierarchy of policies and rules provides standards for handling financial transactions for federal contracts and grants. Starting with the individual award terms and conditions, work up through each layer of regulation to determine what the applicable rules are. Some agencies may add terms and conditions that go beyond the requirements laid out in their agency implementations of OMB Circular A110.

It is very important to read and understand all terms and conditions. University policies and procedures must be followed in all transactions! Many University policies were developed based upon the framework set by the federal government in its financial systems and cost principals. The rules are complex and detailed, always check the exact text of the rule or policy rather than relying on your general recollection! Terms and conditions take precedence over all. When the university accepts the Terms and conditions of an award, we are bound regardless of whether they conflict with university policy.

University Internal Approvals and Expanded Authorities

1. Pre-Award Costs
   To create a sponsored research account for the purpose of incurring pre-award costs up to a maximum of 90 calendar days prior to award start date. Note, however, that any expenditures that precede the award are solely at the financial risk of the unit requesting these expenditures (i.e., PI).
   
2. No Cost Extensions
   To initiate a one-time extension of the award expiration date of up to 12 months (funding agency must be notified of extension at least ten days prior to original termination date). This extension may not be exercised merely for the purpose of using any unobligated balance. Use OSR Form 49.

University Approval Procedures

Internal prior approvals will be made through your Institutional Representative (OSR or RMG). All requests for a no-cost extension must be approved in advance of the original date of project termination, to allow adequate time for agency notification.

Approval Required from the Funding Agency

The Principal Investigator of a federally sponsored project is required to report deviations from budget and program plans, and request prior approvals through OSR/RMG directly from federal awarding agencies for any of the following program- or budget-related reasons:

1. Change in the scope or the objective of the project or program.
   
2. Change in the Principal Investigator.
   
3. Absence for more than three months or a 25 percent reduction in time devoted to the project, by the approved PI.
   
4. Additional federal funding.
   
5. Transfer of funds allotted for training expense (direct payment to trainees - stipend, tuition, fees) to other categories of expense.
   
6. Subawards, transfers, or subcontracting out of a substantive programmatic portion of work, unless described in the application and funded in the approved award.