Changes Requiring Prior Approval
Principal Investigators often want to make changes to the budget, which deviate from the proposal that was approved by the Sponsor. In some cases, it is necessary to request the prior approval of the Sponsor. In other instances, "internal", prior approval by the ORA is sufficient. The level at which approval may be granted depends upon the type of sponsored research award and the Sponsor's specific policies for that type of award. This information is intended to be general reference information. Please contact the ORA Post Award Administrator, if you have any specific questions or need assistance in contacting the sponsor.
Procedure for Initiating Changes Requiring Prior Approval
When prior approval is required by the Sponsor, such requests should be in writing, addressed to sponsor and in advance of the change. Requests for retroactive approval should be avoided. In addition, all requests should be signed by the Principal Investigator and countersigned by an authorized official from the ORA.
Rebudgeting is the process by which the Principal Investigator produces a new revised plan for spending the awarded funds. New budgets may be necessitated by such events as a change in project scope, need for supplemental funding, or the inability to raise matching funds. Most sponsors place restrictions on budget revisions, including moving funds from one category to another. Significant changes to the budget almost always require prior approval by the sponsor.
Change of Scope/Salary Allocation
In general, most Sponsors require that they be informed of any changes that may effect the scope of the actual research to be performed such as an absence/change of the Principal Investigator, change of grantee institution, a change in the approved use of animals or human subjects, or a change in the objective or emphasis of the study. Usually, a significant change (decrease) in the percentage effort devoted by the key project personnel to the project is considered as affecting the scope of the research. Since the Personnel Action Forms provide the documentation of salary allocation devoted to sponsored research awards, it is important that they reflect the effort planned in the approved budget.
Absence or Change of Key Personnel
The prior approval of the awarding agency is required for any absence of the Principal Investigator for a period of 3 months or more. A substitute Principal Investigator may be named or the award will be relinquished. Changes of key personnel whose expertise is critical to the approved project must also have prior approval. The Department Administrator/Principal Investigator must notify ORA of the absence of Principal Investigator "prior" to absence.
The principal investigator may usually approve the acquisition of items of equipment not listed in the approved sponsored research award budget, provided the cost of each item is less than $5,000. Any items over $5,000 necessitate the prior approval of the awarding agency or OSP. Unplanned purchase of equipment under $5,000 not requiring prior sponsor approval, are handled by ORA Post Award Administrator. The Principal Investigator must submit a brief memo stating the cost of the new equipment. No equipment should be purchased during the last 6 months on a grant or contract.
A sponsor's terms and conditions must be followed with regard to foreign travel. Many sponsors require prior approval for foreign travel, even when the foreign travel has been included in the initially approved budget. Requests should be submitted with detailed justification to the ORA Post Award Administrator and will be forwarded to the sponsor. Requests for foreign travel should be made PRIOR to taking the trip and at least 30 days in advance. Note: some sponsors require up to 90 days prior notice.
Unobligated Balances/Carryover Funds
When a sponsor requires prior approval to carryover funds from one budget period to another, the Department Administrator or the Program Investigator needs to submit a formal letter requesting to carryover funds to ORA, the letter needs to be signed by the Principal Investigator and then ORA.
Subawards that were not included in the proposal require the sponsor's approval prior to executing a formal agreement and commencing work. The choice of a particular Subaward must be documented with regard to the subrecipient's qualifications to perform the work and the award's need for such services.