Policies & Compliance

Award Management

9.5 Post-Award Changes and Required Approvals

Sponsored projects frequently evolve after an award is made. Changes to project scope, budget, personnel, timelines, or activities may occur as work progresses. Certain post-award changes - particularly those involving institutional engagement or foreign entities - may require additional institutional and sponsor prior review and approval to address evolving research security requirements.

Whether the prior approval is required depends on:

The type of award (e.g., grant, contract, cooperative agreement);
The sponsor's terms and conditions; and
applicable University policies.

Investigators should consult the Office of Sponsored Projects (OSP) before implementing any substantive change to an awarded project.

Additional guidance is available in Manage Your Award under the Grant Life Cycle.

9.5.1 Changes That May Require Prior Approval

OSP assists in determining whether a proposed change is allowable under the award and whether prior written sponsor approval is required. Many requests must be formally submitted and reviewed or countersigned by OSP before implementation.

9.5.1.1 Re-budgeting

Sponsors may fund projects at a lower level than originally proposed or allow flexibility to reallocate funds during the project period. Significant rebudgeting actions - particularly those that affect project scope or investigator effort - often require sponsor approval.

If a revised budget is requested by the sponsor, it must be prepared and submitted through OSP following standard proposal procedures.

9.5.1.2 Additional Compensation

Payment of additional compensation to faculty or staff beyond 100% institutional effort is permitted only in exceptional circumstances and must comply with sponsor and University requirements.

When an individual's salary is paid in whole or in part from a sponsored project:

any additional compensation must be reviewed and approved through OSP before commitments are made; and
sponsor approval is typically required.

Federal regulations limit total committed effort to 100%, with narrow exceptions (e.g., certain teaching assignments). Sponsored project funds generally may not be used for consulting or honoraria within the same department without sponsor authorization.

9.5.1.3 Changes in Objectives or Scope

Any change that significantly alters the approved scope of work may require prior sponsor approval and institutional review. Investigators must consult OSP before implementing such changes.

9.5.1.4 Absence or Change of Key Personnel

The Principal Investigator (PI) is responsible for the active leadership, oversight, and management of the sponsored project for the duration of the award, as required by University regulation and sponsor terms.

Prior sponsor approval is typically required when:

the PI will be absent from the project for three months or more; or
the PI's committed effort is reduced by 25% or more.

In addition to sponsor requirements, the University requires prompt notification and institutional review when there is a material change in the PI's ability to fulfill required responsibilities under Rule R7-200B, including situations involving extended leave, change in employment status, loss of eligibility, or other circumstances that affect project oversight.

Changes involving other key personnel whose expertise is central to the project may also require sponsor and/or University approval. Replacement or interim personnel must have appropriate qualifications and institutional approval prior to assuming responsibilities.

Investigators must consult the Office of Sponsored Projects (OSP) before implementing changes to key personnel or project leadership. Sponsor approval may be required, and submission of a change request does not guarantee approval.

9.5.1.5 Foreign Travel

Foreign travel associated with sponsored projects may require additional review and prior approval, even when included in the originally approved budget.

In addition to sponsor requirements, foreign travel may be subject to foreign influence concerns, research security, export control, restricted-party screening, and disclosure obligations, depending on the destination, sponsor, funding mechanism, and nature of the research activity. Federal sponsor policies related to international travel continue to evolve, and compliance expectations may vary by agency.

Investigators should consult OSP and the Research Security Office before committing to international travel to determine whether additional review, documentation, or sponsor notification is required.

9.5.1.6 New Subawards or Subagreements

Subawards not identified in the original proposal generally require prior sponsor approval before execution and commencement of work.

Subawards - particularly those involving foreign institutions or entities - may also be subject to enhanced compliance and research security review, including restricted-party screening, anti-human trafficking compliance, assessment of data access or information-sharing risks, and evaluation of sponsor-specific requirements related to foreign engagement.

Investigators must work with OSP to initiate and modify subawards. OSP will coordinate with other institutional partners as appropriate to ensure compliance with sponsor, federal, and University requirements before execution.

9.5.1.7 No-Cost Extensions

Sponsors generally expect work to be completed within the approved project period. However, a no-cost extension (NCE) may be requested when additional time is needed to complete the original scope of work using remaining funds.

Federal agencies do not consider unspent funds alone sufficient justification for an extension. Many federal sponsors authorize institutions to grant a one-time extension of up to 12 months under expanded authorities, provided timely notice is given.

Requests for NCEs should be submitted to OSP at least 60 days prior to the scheduled project end date.

9.5.1.8 Carry Forward

Sponsors differ in their policies regarding the carryforward of unexpended funds between budget periods. Investigators must consult OSP to determine the applicable requirements for each award.

9.5.1.9 Relocation or Transfer of Awards

9.5.1.9.a PI Transfers to Another Institution

Because awards are made to the University, any transfer of a sponsored project requires:

sponsor approval;
institutional approval by the University; and
acceptance by the receiving institution.

The PI must notify both OSP and the sponsor well in advance of departure and initiate the transfer request. OSP coordinates all relinquishment actions with the sponsor and the receiving institution.

Transfer approval is not automatic; sponsors may decline or impose conditions. Prior to transfer, all required final reports (technical, financial, invention, property, etc.) must be submitted.

As an alternative, the University may issue a subaward to the new institution when appropriate and mutually agreeable.

9.5.1.9.a.1 Equipment and Property

Transfer of equipment requires:

- a completed Retirement Transfer Form;
- justification for the equipment's continued use at the new institution; and
- written acceptance of ownership and shipping responsibility by the receiving institution.

Property Accounting must approve all equipment transfers.

9.5.1.9.b PI Leaves and Award Remains at the University

If the University elects to retain the award:

a new PI must be nominated;
sponsor approval is required; and
OSP must submit the change request supported by justification, credentials of the proposed PI, and any related budget or scope changes.

Approval of a PI change is subject to sponsor discretion.

Go to Section 9.6 >>