During the lifecycle of an award, there may be a need to make changes in the scope, time, staff, or budget based on a number of circumstances. The following outlines the notifications and approvals necessary to make such changes, both internally and with the funder.
First and foremost, Principal Investigators should always follow the guidelines in the relevant sponsor’s guidelines.
Any request for changes to an award should be made as soon as possible once you are aware of the need, and no later than the date limitations outlined in the University’s or the sponsor’s guidelines.
During an award, a Principal Investigator (PI) may want to make changes to the budget or to modify other aspects of the project. In some cases, the changes may require only internal approval by the University and in other cases such changes may require approval of the sponsor prior to the change. Re-budgeting and Prior Approvals procedures vary from sponsoring agency to sponsoring agency and it is the responsibility of the PI to review and be familiar with the procedures of their project sponsor (including non-government sponsors).
Below constitutes some general rules. As policies do vary from sponsor to sponsor and are amended from time to time, PIs are ultimately responsible for being familiar with their sponsor’s requirements at the time the award is made.
When do I need prior approval?
General guidelines for changes requiring prior approval
Most sponsors will require obtaining their approval prior to the following changes:
- Change in the objectives or scope of the project
- “Significant” re-budgeting which is often defined as transferring over 25% of the award among direct cost categories
- Absence of or significant change of PI or other key personnel effort
- Change of grantee institution
- Need for additional funding
- Transfer of a “significant part” of the programmatic effort to a third party
- Transfer of Participant Support costs to another budget category
- Application of new technology
- Change in the approved use of animals or human subjects
- Pre-award spending more than 90 days prior to the award start date
Clark University requires internal approval on the changes listed above in addition to the following budget revisions:
- Pre-award spending within 90 days of the award start date
- Re-budgeting which moves funds into salaries/support costs for the PI
Procedures
Procedures for review and approval
All re-budgeting and prior approvals requests must:
- Occur prior to any changes or actions, and
- Be submitted through OSPR whether they require sponsor approval or internal approval.
All requests should be emailed to OSPR with a description of the change requested including a justification for the change. OSPR will advise the PI as to next steps in obtaining approvals.
- In the case of re-budgeting requests requiring internal approval only, OSPR staff will review and consult with the Dean of Research to make a determination. Once the determination is made, notification will be sent to the PI, and to Grant Accounting if applicable.
- When sponsor approval is required, OSPR staff will work with the PI to create the request. OSPR will contact the sponsor with the request in most cases, either via email or through the appropriate research administration portal, e.g., Research.gov.
Budget revisions will be denied when:
- the requested revision does not comply with funder and/or university guidelines, requirements, and/or terms and conditions for allowable expenditures and/or budget revisions.
- required prior approval from the funder is denied.
- there is insufficient lead time to process and approve the request per funder guidelines.
- there is insufficient documentation or justification for the request.
- the timing of the revision is at such a point in the period of performance that the intended expenditure may not benefit the project to the extent intended by the funder during the award period.
Time extensions
All sponsored projects are awarded for a specified time period based on the sponsor’s confidence that the proposed project period is reasonable and consistent with the project objectives. Due to a number of circumstances, there may be a need to request additional time to complete a sponsored project, even if no additional funding is being requested, i.e., No Cost Extension. Similar to budget revisions, sponsor guidelines vary and some requests for time extensions can be approved internally, and others required sponsor approval.
All requests for time extensions must be submitted through OSPR whether they require sponsor approval or internal approval. Request for a time extension should be made at least 90 days prior to the end of the approved award period.
