45.14 - Sponsored Projects Changes Requiring Prior Approval from Sponsor
December 2018 (rewrite)
A. Overview. Changes to a sponsored project that require prior approval from the sponsor are to be coordinated through the unit/college, and the Office of Sponsored Programs (OSP) and approved by OSP. Such changes can include, but are not limited to:
a. A change to the period of performance;
b. A change in the status of the Principal Investigator (PI), co-PIs or other key personnel working on the project (including changes to level of effort greater than 25% or as required by the sponsor, PI/Co-PIs departure from the University, project transfer or relinquishment requests, etc.);
c. Changes to line-item budgets not falling within the authority prescribed by a sponsor (also known as "rebudgeting" greater than as allowed by the award terms). Note that rebudgeting more than 25% of the award funding requires a justification from the PI to confirm the scope of work is not changing (whether or not sponsor approval is required);
d. Rebudgeting of participant support costs;
e. A change to the approved scope of work, project methodology, objectives, or deliverables;
f. Subawards and foreign travel (for certain sponsors, prior approval is required even if proposed);
g. Any other changes requiring prior sponsor approval, as determined by the terms and conditions of the specific award and/or by the applicable regulations of the sponsoring agency (e.g. some equipment purchases, subawards not initially proposed, travel not proposed, carry-forward of funding, cost sharing, and pre-award costs).
Whether prior approvals are required is determined by specific award terms and conditions and by the general terms and conditions or applicable regulations of the sponsoring entity. A prior approvals matrix that defines the specific requirements for select sponsors is available on the OSP website and is regularly updated by the National Science Foundation on their grants terms and conditions (policy) website. Contacting the OSP Post Award and/or Cost Accounting Unit for a determination on the need for prior approvals is best practice.
B. Policy. Principal Investigators are responsible for review of the award document(s) and for contacting OSP, if there are questions regarding specific deadlines.
To allow time for processing by OSP, a request for an extension of time must be submitted a minimum of five (5) working days prior to the sponsor submission deadline. Sponsor submission deadlines are typically 10-30 days for first-time extension requests and 45 days for any subsequent extension requests.
Requests for sponsor approval of any other changes should be received by OSP and approved by the authorized official of the UI 30 days in advance of the requested effective date of the change. Note that some sponsors require more than 30 days advance notice.
Requests made outside of the sponsor submission deadline may be declined by OSP or be rejected by the sponsor.
Because OSP is responsible for the monitoring of all regulations and obligations associated with sponsored program funding, OSP (as the VPRED designee) serves as the final University approval for all proposed changes.
C. Procedural and Contact Information. See the OSP website for sample letters and procedural guidance. For questions or additional information, please contact the Office of Sponsored Programs at 111-111-6651 or [email protected].