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). 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/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.
Various federal agencies have implemented these Research Terms and Conditions and the need for prior sponsor approval. The following resources are available to help identify how various federal agencies have implemented these Research Terms and Conditions and the need for prior sponsor approval.
Prior Approval Matrix
- Research Terms and Conditions Appendix A Prior Approval Matrix (06/30/2017)
- Use for NSF, DOE, NIH, USDA/NIFA
- OSP Uniform Guidance (A-81) Prior Approval Matrix (09/15/2015, Rev. 05/25/2017)
- Use for all other federal agencies
- Research Terms and Conditions Prior Approval and Other Requirements Matrix (October 2008)
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, the OMB Circular A-81 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)