Since your proposal budget is only an estimate of your project’s financial needs, it’s not unusual for those needs to change from what you anticipated once a project is underway. While Uniform Guidance and certain sponsor-specific terms and conditions grant you some flexibility to deviate from the approved proposal budget, in some instances prior approval is required. These requirements vary depending on the sponsor, but there are some basic principles that can help determine if sponsor approval is needed. (Other non-financial changes to an award may also require prior sponsor approval.)
- Change in Scope: If the proposed changes to the budget would result in a change in the scope of the project, sponsor approval is most likely required prior to making the change.
- Addition of a Sub-award: Any sub-awards or subcontracts not included in the approved proposal budget will likely require sponsor approval.
- Capital Equipment: Some sponsors (e.g., NASA) require prior approval for any unbudgeted items of equipment over $5,000, while others require approval for equipment items that exceed other sponsor-defined thresholds. PIs should discuss proposed unbudgeted equipment purchases with their post-award administrator prior to placing the order.
- Reduction of PI/Co-PI effort of 25% or More: Any budgetary change that results in a reduction of 25% or more in the effort of the PI or Co-PI requires sponsor approval if it is a federally funded award.
- Line Item Deviations of 25% or More: The NIH Grants Policy Statement notes that deviations among cost categories of 25% or more of the total amount awarded may require sponsor approval as this may indicate a change in scope.
- Reallocation of Trainee/Participant Support Costs: Any re-budgeting that affects line items with funds for NIH Trainee Costs or NSF Participant Support Costs requires sponsor prior approval.
Other Prior Approval Requirements
- No-cost Extensions: Many federal sponsors grant us the authority to initiate a one-time no-cost extension of up to 12 months without prior approval. These agencies must still be notified of the extension, but such notifications are not “requests” for approval. For all other sponsors, extension of the end date of the award requires prior approval, and even for sponsors who authorize a first no-cost extension without approval, any additional extensions require prior approval. See more on the No-Cost Extension section of our website.
- Long-term Absence or Disengagement of the PI or Co-PI: If a PI or Co-PI will be “absent” (NIH’s term) or “disengaged” (NSF’s and Uniform Guidance’s term) for a period exceeding three months, sponsor approval is required. In some cases, a replacement PI or Co-PI may be appropriate to ensure adequate oversight of the project.
- Removal of a PI or Co-PI: While the exact details vary by sponsor, in general, the removal from PI status of any PI, Co-PI, or Senior/Key Personnel specifically named in the sponsor’s notice of award requires prior sponsor approval.
- Transfer of an Award: If a PI with active sponsored projects leaves the University of Pittsburgh, they may request the transfer of any active awards to their new institution. Because awards are made to the institution, and not to the PI, such transfer requests are made at the discretion of the department and school. See the PIs Leaving Pitt section of the Office of Research Protections website for more information on transferring awards.
How Do I Request Sponsor Prior Approval?
- All prior approval requests should be coordinated with your post-award administrator; you should not directly contact your program officer. There may be occasions where a conversation with your PO is appropriate in advance of a prior approval request, but in most cases, the formal request should come from the Office of Sponsored Programs.
- If you are contemplating any of the circumstances listed above that may require prior approval, contact your post-award administrator, and they will advise you if sponsor approval is required and what you need to start the approval process.