Prior Approval Requests
Changes resulting from circumstances not anticipated during the proposal stages of the project are sometimes necessary after an award is made. These changes can be programmatic or financial in nature. Some changes require the sponsor’s prior written approval, others may be authorized internally by the Office of Sponsored Projects (OSP). All ITS Infrastructure Bundles and ITS FTE billing charges require prior approval by OSP. Please refer to Policy 1403 and Form 1403 FR.02 for more information.
The level at which approval may be granted depends upon the type of sponsored research award and the Sponsor’s specific policies for that type of award. Refer to the sponsor’s guidelines, award documents and contact your OSP Award Manager or Contract Manager with specific questions regarding such changes.
The Federal Demonstration Partnership (FDP) is a cooperative initiative among certain federal agencies and institutional recipients of research funds of which Yale is a member. The FDP developed standard Research Terms and Conditions (RTC) now in use by several federal sponsoring agencies. Visit the Federal-Wide Research Terms and Conditions page on the NSF website for an explanation of each of the Research Terms and Conditions as well as a link to each participating federal agency’s specific RTC.
For Non-Federal sponsored programs (e.g. industry, foundations, foreign government, non-profits), consult the terms of the agreement for guidance as requirements vary depending on the sponsor’s policies. If the award does not include specific requirements, Principal Investigators (PIs) should follow the guidance for Federal grants and cooperative agreements when considering any of the programmatic or financial changes listed below.
An authorized official from the Office of Sponsored Projects (OSP) must sign all prior approval requests to sponsors.
Initiating Prior Approvals
Prior approval is required in advance of the change. Requests should be in writing, addressed to the sponsor, signed by the Principal Investigator and countersigned by an authorized official from the Office of Sponsored Projects (OSP). The request should be submitted to OSP via the appropriate gcat mailbox.
Examples of programmatic and financial changes during the life of an award:
- Changes in the scope of work (SOW)
- Change of Principal Investigator or significant reduction of effort
- Change in Key Personnel
- Changes/additions to collaborating institutions/subcontractors responsible for carrying out a portion of the SOW
- For federal awards, 2 CFR Part 200, Uniform Guidance grants permission to an awardee to re-budget, except where there is a change in the SOW or the need for additional funding
- Non-federal awards may provide different thresholds for re-budgeting, for example by percentage, amount of deviation by budget category or line item, or stipulate that “substantial” deviation requires prior approval
- Carry-forward of funds from one budget period into the next within a project period
- Supplemental Funding Request (see also Proposals)
- No cost extension of the budget or project period (extension of time without additional funds)
Prior Approval Letter Templates
The below templates are sample letters to be used as guides when requesting prior approval from a sponsor.
- Prior Approval: Change in PI
- Prior Approval: Change in Scope of Work
- Prior Approval: Reducing the level of effort
- Prior Approval: Relinquishing/transferring an award to a new institution
- Prior Approval: Second No Cost Extension (NCE)
Attestation Letter Templates
The attestation letter templates can be used when PIs need to certify that the work to be completed on an award will not involve human subjects and/or animals without a valid IRB or IACUC protocol approval in place.