Project Change Approval
Each sponsor may have specific requirements regarding changes to the scope of the project or modifications to the approved budget. Any changes should be discussed first with your Grant Coordinator. This is especially important regarding changes in project duration or the budget as Research Services may have expanded authority to approve changes to certain grants without referring back to the sponsor.
What type of changes generally require prior approval by the sponsor?
For grants/contracts requiring sponsor’s prior approval, correspondence with the sponsor requesting such changes must be discussed with the grant coordinator prior to submission in order to be approved and executed on behalf of the University and PI. Once approval is received from the sponsor, the investigator and other academic and administrative units will receive notification.
Types of Prior Approvals
- Change in Scope of Work
- Change of Key Personnel
- Key Personnel disengagement of 3 or more consecutive months, or decrease in effort of 25% or more
- Transfer of award to another institution
- Pre-award costs over 90 days
- No Cost Extensions
- Adding to the award budget: Equipment, land acquisition, construction/renovation, administrative or clerical salaries
Prior Approval Requests from Subrecipients
- Subrecipients should always submit their prior approval requests to the pass-through entity (i.e., Georgia Southern University)
- Only an Authorized Organizational Representative (AOR) can approve the request (if it falls under Expanded Authorities).
- An amendment will be issued to the subrecipient documenting the change.
- Prior approval requirements DO NOT flow down to subrecipients.
- Expanded authorities DO NOT automatically flow down to subrecipients (i.e., pre-award expenditures, no-cost extensions)
What is expanded authority?
Some agencies give expanded authority to the awardee institution to approve select changes in certain grants without referring back to the sponsor. Some limitations to expanded authority are listed below:
- Only used for changes that are necessary for the completion of the project within the original scope of work (SOW) and budget
- Only apply to grants and cooperative agreements
- Does not automatically apply to subawards
- Agencies that exercise Expanded Authorities: ONR, NASA, NSF, USDA-NIFA, OE, NIH (and other PHS agencies), NOAA, DOE, EPA, ARO, and DOT Codified in 2 CFR § 200.308(d)
What types of changes may fall under Expanded Authority that can be approved by the university?
- Pre-award Costs. Agencies may waive prior approval of costs up to 90 days prior to the start date of an award. Pre-award costs must be necessary (not for convenience). For example, purchasing equipment or animals 6 weeks in advance so when the items arrive, work can begin on the start date. Pre-award costs > 90 days requires agency approval.
- Carry Forward. Agencies may allow unobligated balances to be carried forward into subsequent years. Always check the sponsor terms and conditions, as well as the award document for guidance and restrictions on carry forward.
- Rebudgeting. Agencies may restrict rebudgeting (if the award is over the Simplified Acquisition Threshold) among direct cost categories to 10% of the total cumulative budget.
- No-Cost Extensions. Agencies may allow a one-time no-cost extension of up to one year beyond the original end date for additional time to complete the scope of work; complete an orderly phase out of the project; or a competing application is under review while work continues. Unspent funds are never an appropriate justification for a no-cost extension.
Last updated: 4/27/2021