Prior approval is the written permission by an Authorized Organizational Representative (AOR) at The Research Foundation in advance of an administrative action that would result in a change in budget and/or program plans on a sponsored award.

Prior Approval Requirements are found in the OMB Uniform Guidance section 200.308.

For most Federal awards, prior written agency approval is required for the following changes:

  • Change in the objectives or scope of the project (even if there is no associated budget revision);
  • Change in the key person(s) specified in the notice of award;
  • Need to charge salaries of administrative and clerical staff as direct costs (unless included in the approved proposal);
  • Disengagement from the project for more than three months by the approved project director or Principal Investigator (PI);
  • Reduction in Effort devoted to the project by the PI or key person(s) specified in the award notice by 25% or more;
  • Transfer of Participant Support/trainee costs to another budget category;
  • Addition of a foreign component;
  • Transfer of a significant part of the programmatic effort to a third party via a subcontract not included in the approved proposal.
  • Need to issue a fixed price subaward;
  • Change in the approved cost sharing;
  • Change in the approved use of animals or human subjects;
  • Change of grantee institution;
  • Need for pre-award spending more than 90 days prior to the award start date
  • No-cost extensions to the period of performance beyond the first no-cost extension of up to 12 months.
  • Carry-forward of funds of the current year budget (including prior year carry-forward funds) into the next budget period within a project period, unless an award has carry-forward authority.

Non-Federal sponsors may have similar, additional, or less restrictive requirements for prior approval.

See – Expanded Authorities or Waiver of Authorities