9.5 Post-Award Changes & Approvals
Frequently, projects change or evolve from how they were initially proposed to or awarded by the sponsor. Some changes occurring over the life of the project require prior written approval from the sponsor and/or OSP. The level at which approval may be granted depends upon the type of award and the sponsors terms and conditions governing the award.
See also Manage Your Award in the Grant Life Cycle.
OSP can help determine whether the terms and conditions of an award permit a change or require prior approval from the sponsor. A request for modification may need to be in writing and reviewed and/or countersigned by OSP.
A sponsor may wish to support a proposed budget, but at a reduced level of funding. If requested, a revised budget should be submitted to OSP for review and submission according to the same procedures followed for new proposals. Reductions in proposed budgets should be evaluated to determine whether there is a change in the PI’s level of effort or to the scope of work.
Significant changes to a budget tend to require prior approval by the sponsor.
Additional Compensation for work over and above the 100 percent of effort may be paid to a faculty/staff member only in exceptional circumstances.
If an individuals salary is paid in whole or in part from a sponsored project, the payment must be approved through OSP before the commitment is made or the additional work is carried out. Under most circumstances, OSP will obtain the sponsor's approval before signing the additional compensation form. The reason for this approval is that the federal guidelines, OMB A-21 Section J.8.d.1, state that an individual may only commit 100% of their time. Additional work changes the percent of effort expended on a grant or contract (one exception to this is teaching summer or continuing education courses). In addition, if the additional compensation is to be paid from a sponsored project, OSP must verify that the budget approved by the sponsor allows payment for consulting or honoraria. Generally all consulting using federal funds MUST be across departmental lines as stated in the OMB A-21 reference above. So payment from a sponsored project to an individual who resides in the same department as the principal investigator of the grant or contract will be allowed only with sponsor approval. Additional compensation forms (PDF) will be forwarded to OSP for a signature, if required.
Changes that significantly alter the scope of work as proposed may need to be approved by the sponsor and/or the University.
Prior approval of the awarding agency is normally required for any absence of PI/PD for a period of 3 months or more or a reduction of effort equal to or exceeding 25%. A substitute PI/PD may be named or the award may be relinquished. In general, changes in key personnel whose expertise is critical to the project must also have prior approval.
Foreign travel may require special review, even when the travel has been included in the initially approved budget.
Subcontracts not included in the original proposal usually require the sponsor’s approval prior to executing a formal agreement and commencing work.
The PI is expected to complete work under sponsored agreements within the project period specified in the award. However, if the PI needs additional time to complete the approved scope of work, using existing funds, the sponsor may consider a request to extend the expiration date of the award at no additional cost. Federal sponsors do not consider funds remaining at the end of the award as sufficient justification for an extension of time. Normally, no single extension may exceed twelve months and only in exceptional cases will more than one extension be granted.
Some federal agencies under the guideline of "expanded authority" allow the University to grant a one-time, up to one year, no-cost extension so long as notice is sent in a timely manner. Reasons for granting an extension may include: 1) time to finish the scope of work; 2) a request for continuing funds is under review or; 3) to allow time to finish closeout procedures. Contact your OSP Administrator at least 60 days before the expiration date of the grant to make your request.
Carry forward of funds that are unspent at the end of the budget period in a multi-year project are dealt with differently by different sponsors. OSP should be consulted for the specific requirements of the award and agency.
Transfer of an award when the PI or project moves from one institution to another usually requires:
- Prior approvals from the sponsor
- Prior written approval from the University
- Written approval/acceptance from new recipient institutional official(s)
All transfers begin at the institution the PI is leaving, and it is his/her responsibility to initiate the process. Prior to changing institutions, the PI must notify both the Program Officer/contact at the granting agency, and OSP.
Because awards are made to the University, the University must agree to any proposed transfer via the Relinquishing Memo (DOC). Read more on Institutional Transfers and the NSF and NIH transfer processes.
PI’s should reconcile with OSP all pending proposals and active awards by indicating which projects they desire to transfer and preparing a letter requesting approval to transfer.
The Relinquishing Memo and the approvals by chain of authority, including the Chair of the administering department and the VP for Research, should be initiated by the PI and be submitted to OSP several months prior to departure. Upon receipt of this approval, OSP may, if applicable:
- Check sponsors policy on transferring of proposals and awards
- Prepare a letter stating the University’s desire to relinquish all rights and interests to the award
- Initiate relinquishing process with sponsors Contracting Officer
- Terminate contracts, if not able to transfer
- Forward all relinquishing documents to the new institution as needed
- Satisfy sub-contract requirements
- Terminate sub-contracts, as needed
- Revise project end dates, as needed
Submission of the relinquishing statements from the University does not guarantee sponsor approval to transfer the award. Only upon receipt of a sponsors approval is the award officially transferred. If/when a sponsor agrees to the transfer, it will still be necessary to provide, prior to official transfer, a final progress report, final invention statement, final financial status report, and final property report.
As an alternative, the University may issue a sub-award to the new institution for the remainder of the project if time and funds remaining are modest and both sides agree.
The PI may need to provide adequate justification of the need for the equipment at the new institution. A letter must also be obtained from the new institution stating that it will accept title and assume financial responsibility for packing and shipping the property. Once approved, the University may allow the transfer of equipment items. There may be times that the University requests that items be purchased. The department may need to verify and/or certify that only the approved property has been packed and shipped, depending on the requirements of the new institution.
In this case, the University has chosen not to relinquish the award. Therefore, the University will propose a new PI to the sponsor, as informed by the department. In order to initiate a change of PI, OSP should be provided with:
- A justification for the change
- The curriculum vitae of the proposed replacement
- A summary of the proposed PI’s qualification specific to the project
- Any programmatic and/or budget changes resulting from the proposed change
Before a change of PI can take effect, the sponsor must approve this request prior to physically changing the status on an active award. Submission of a PI change request does not guarantee sponsor approval.