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Reminder

Compliance protocols MUST be approved and linked in SeRA to a SPO project record prior to award acceptance. 

See ORA's Award Acceptance Resources for additional information.

Prior Approvals & Notifications

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Most sponsors require written sponsor prior approval be requested and obtained for significant changes to a sponsored project from that which the sponsor awarded.  Identifying what project changes require sponsor prior notification or approval, watching for these, and alerting your investigators as thresholds are approached over the life of a project is one of the most value-add functions a department research administrator provides their investigators as part of sponsored portfolio management.

Sponsor prior approval/notification requirements are typically indicated in the sponsor Notice of Award (NOA) and/or relevant sponsor guidelines, but beware, sometimes you must do some digging to find them.  For example, the NOA may refer to terms by a web link.  You need to follow the link(s) until you arrive at the actual text of the terms that advise when sponsor notification or prior approval is required.

For common project changes, some sponsors require only prior notification of the change.  Once we notify the sponsor of the project change, it’s immediately effective. For example, 1st No Cost Extensions on most direct from NIH and NSF awards.  

There is NOTHING wrong with seeking sponsor prior approval for a project change(s).  However, they do take time and are not guaranteed to always be approved.  

Where possible, build proposals that have enough flexibility and forethought to preemptively minimize sponsor prior approval requests if the project is awarded.  For example, if post docs in your department are regularly appointed at salaries well above the Stanford minimum post doc salary rates, it would be prudent to budget post docs at the salaries your department regular pays to avoid a predictable personnel budget shortfall.  Remember, effective project management starts at proposal development!

What Project Changes Require Sponsor Prior Approval?

Project ChangeNeed Sponsor Prior Notification or Approval?
Change in ScopeYes, always!
Change in PIYes, always!
Adding a subaward that was not proposedNearly always, refer your award and sponsor terms
RebudgetingIt Depends, refer to your award and sponsor terms
Adding foreign travel that was not proposedIt Depends, refer to your award and sponsor terms
Purchasing capital equipment that was not proposedIt Depends, refer to your award and sponsor terms
CarryforwardIt Depends, refer to your award and sponsor terms

Timeliness

Sponsor notifications/approvals requests should nearly ALWAYS be submitted PRIOR to the project change occurring.  "Retroactive prior approval” requests are almost never appropriate and significantly increase the likelihood of a request being denied and/or that a project will be audited.

Note, some sponsor notifications/prior approval requests, notably No Cost Extensions (NCE/NCX) have hard deadlines.  Plan accordingly, including accounting for Stanford Central Office (OSR, RMG, ICO) processing time = 5 full business days before any sponsor notification/request deadline.

SponsorRequest TypeSubmission Deadline
NIH1st No Cost Extension (NCE/NCX)Project End Date
NIH2nd or greater No Cost Extension (NCE/NCX)30 Calendar days prior to the project end date
NSF1st No Cost Extension (NCE/NCX)10 Calendar days prior to the project end date
NSF2nd or greater No Cost Extension (NCE/NCX)45 Calendar days prior to the project end date

Who Does What

  1. PIs write the scientific justification.
    • Always address why is the change for which approval is being requested is essential to the project/how does this change help the PI complete the sponsor approved statement of work for the project? Sell it! 
  2. Department research administrators prepares supporting administrative components.  For example, revised budget(s) etc. 
    • Always tell the story!  What is going on here?  How did we get here, and where are we going?
  3. Institutional Officials review and submit requests to a sponsor's grants management officer or equivalent at sponsor.

How and Where to Prepare Prior Notification and Approval Requests

  1. Prepare the notification/request as prescribed by the given award and sponsor.  Refer to award terms and conditions for appropriate submission process to sponsor.

    SponsorWhere/How to Submit Prior Notifications or Approval Requests
    NIHMost NIH notifications/requests are prepared and submitted through eRA Commons
    NSFMost NSF notifications/requests are prepared and submitted through Research.gov
    Other Federal SponsorsIt depends – Refer to the award’s T&C
    Other Non-Federal SponsorsIt depends – Refer to the award’s T&C
    Subawards/Pass-Through-Entities (PTEs)Typically, Stanford’s OSR emails the notification/request to the Pass-Through-Entity’s OSR/business office.
  2. Prepare and route appropriate SeRA Central Office Request to internally record the notification/request and prompt your institutional official to review and submit the notification or request to the sponsor.
    • OSR & RMG strongly recommend departments prepare & submit to OSR or RMG sponsor notifications/requests and the associated SeRA Central Office Request at least 5 full business days before any sponsor notification/request deadline.

Important Prior Notification and Approval Notes

  • For NIH projects, we may include certain prior approval requests as part of annual/interim reporting in Research Performance Progress Reports (RPPRs).
    • For example, if in a Yr 1 NIH RPPR you were to indicate the PI will reduce their effort on the project significantly in Yr 2,  and the Yr 2 NOA is subsequently issued by NIH and makes no mention of NOT approving what was included in the Yr 1 RPPR, you can consider the PI effort reduction notification/request as NIH/sponsor approved.
  • For subawards, Pass-Through Entities (PTEs) may and often are more restrictive than a prime sponsor.  For example, just because a prime sponsor and award allow for rebudgeting does NOT automatically mean the PTE rolled that rebudgeting authority down to us at Stanford.
    • How do you know?  - Refer to the terms and conditions of your subaward in SeRA!
  • Some rules are inflexible. If a sponsor outlines unallowable costs in their program and/or award terms, we cannot and should not request approval to spend in those categories.
  • Program officer approval does NOT usually = official approval from sponsor.  In most cases we need approval in writing from the sponsor’s business office. 
    • Likewise for subawards, the Pass-Through PI’s approval does not usually = official approval from sponsor.
  • Terms can change over the life of an award, so before submitting a prior approval request review all award notices in SeRA Stanford has received to date for the given project to confirm we have not already sought and received approval for the given project change.
  • A conversation between PI and Program Official ahead of formal request can significantly facilitate and expedite prior approval requests, especially if the request falls into a gray area.  However, keep in mind these conversations usually do NOT result in formal sponsor approval, and rather can be thought of as an endorsement.
  • For complicated/multi faceted requests, combining the individual requests into one, to the extant the given sponsor allows for this, can be advantageous and reduce back and forth with the sponsor.

Prior Approval Resources


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