Prior Approval & Other Requests
During the life of a grant, it is likely that changes will be needed that deviate from the submitted proposal. At times, these changes require prior approval from the sponsor. What requires prior approval or not is dependent on the sponsor’s award terms and conditions. Terms and conditions vary by sponsor so it is the PI’s responsibility to review and familiarize themselves with their award’s terms and conditions to ensure they are in compliance. For example, a private foundation’s prior approval terms and conditions typically differ from the prior approval terms and conditions of a federal sponsor. For more information on prior approvals from the most common federal sponsors, please refer to the NSF Research Terms & Conditions (Research Terms and Conditions Appendix A – Prior Approval Matrix).
The most common requests types are:
- No Cost Extensions
- Re-budgets
- Carry-forward
- Changes to Key Personnel
- Changes to Effort
Examples of circumstances requiring prior approval from a sponsor include, but are not limited to:
- Changes in the scope or the objective of the project
- Changes in the Principal Investigator or Key Personnel
- Absence for more than three (3) months, or a 25% reduction in the time devoted to the project by the Principal Investigator or Key Personnel
- Transfers of funds allocated for training expenses (direct trainee payments, stipends, tuition, fees) to other budget categories
- Subcontracting a substantive programmatic portion of the scope of work
- Equipment not approved in the original award
Official prior approval requests must be submitted by the OSP. Prior to implementing any significant changes, a PI must review the award’s terms and conditions. If a PI is uncertain as whether a change requires sponsor prior approval, he/she contact their assigned Grant Accountant or an OSP post-award team member to determine if the change requires the sponsor’s prior approval or not. When the sponsor’s prior approval is required, OSP will determine what information, data, etc. is required and will guide and assist PIs in drafting prior approval requests. Ultimately, OSP is responsible for submitting official prior approval requests. If the prior approval request is approved by the sponsor, OSP will notify the PI, the assigned Grant Accountant and other necessary parties.
For more information, please contact a member of OSP’s post-award team:
Catherine Bruno, Senior Post-Award Officer at brunoc@517b2b.com or 973-655-6923
Kate Dorsett, Post-Award Officer at dorsettk@517b2b.com or 973-655-6927
Updated October 26, 2023