Prior Approval for Post-Award Changes

When researchers consider rebudgeting or other post-award changes and are uncertain about the allowableness of such changes — particularly when such items are not mentioned in the regulations, cost principles or other policy documents — they are strongly encouraged to consult in advance with the designated Grants Management Officer and the Office of Research’s Award Administration Office. Some of the most common post-award changes that require agency prior approval are:

  • Changes in the scope or objectives of the grant-supported activities.
  • Significant change in responsibilities or replacement of the approved project director (PI), or other persons expressly identified as key personnel by the agency in the Notice of Grant Award, or by the Grantee in the application.
  • Continuation of the project during any continuous period of more than 3 months without the active direction of an approved project director or PI.
  • Where the need for patient care in the project has not previously been approved by the agency.
  • Undertaking any activities or expenditures disapproved or restricted as a condition of the award, including restrictions imposed by standard provisions such as cost principles.
  • A request for additional federal funds, excluding those situations where the need for additional funding results from an increase in the base upon which indirect costs are calculated (due to otherwise allowable rebudgeting actions such as rebudgeting into the personnel category whereby allocations of indirect costs increase).
  • The transfer of amounts previously awarded for trainee costs (stipends, tuition, and fees) to other categories of expense. Rebudgeting within the category of trainee costs or into the trainee costs category is allowable without the awarding office’s prior approval.