Award Management - Prior Approvals
Although many sponsored awards allow flexibility in areas such as rebudgeting, carryforward of unobligated balances from budget period to budget period, and pre-award spending, sponsors’ expectations are that expenditures be reasonably consistent with the proposed scope of work and budget. Many federal agencies have delegated expanded authority to the University for rebudgeting, pre-award spending, single no-cost extensions, etc. The Department and PI should refer to the award documents uploaded in the IORA Award module to review sponsored award terms and determine the authorizations that apply to each award.
Federal Circular A-110 and 2 CFR 200 require PIs to request prior approval for significant changes that affect the scope of work (change in project objectives, change in key personnel) and budget (rebudgeting of restricted funding). Federal guidance and your award may address other situations where prior approval is required. Most federal sponsors require that an Authorized Business Official (ORPA RA) submit any prior approval requests.
The Prior Approval and Other Requirements Matrix contains prior approval requirements for multiple federal government agencies.
Some awards may not allow automatic carryforward of unexpended funds for each budget period. The Department and PI must review the sponsored award terms closely to determine whether carryforward of unexpended funds is restricted and therefore requires prior approval. Please note if carryforward requires prior approval, a new GR5 is required for each budget period.
For NIH awards, awardees now have the ability through their Authorized Business Official (ORPA RA) to submit a carryover request through the Prior Approval module of the Commons. Specific information must be provided to your ORPA RA to allow them to make the request using the Prior Approval module. Please use the NIH Carryover Request form to assist you in gathering all of the necessary information.
An NIH grant is not eligible for a carryover request via the NIH Prior Approval module when the project period has ended, when the grant is in closeout status or when a no cost extension period has not been approved. For carryforward between budget periods, a prior approval request cannot be submitted until the financial report disclosing the unexpended funds has been accepted by NIH.
(Note: When NIH carryforward is automatic, the carryforward of unexpended funds between competitive segments may be made available upon NIH acceptance of the final financial report (for the previous competing segment) and the release of a subsequent carryforward notification letter received by ORACS. This carryforward will be recorded in the UR financial system only.
For carryforward requests to other sponsoring agencies, please contact your ORPA RA for agency specific instructions.
Change of UR PI
Prior sponsor approval is required when a change of PI is necessary. ORPA can submit the request for prior approval upon receipt of certain required documents supporting the change. Documents needed may include a justification for the change, new PI Biosketch and Other Support as well as information regarding level of effort to be devoted to the project. In most cases, prior approval for a change of PD/PI on an NIH grant can be requested via the eRA Commons Prior Approval Module. A completed NIH Prior Approval for Change of PD/PI form must be submitted to ORPA to initiate the request. Please contact your ORPA RA for further information. Existing unfunded agreements (DUA and MTA), when applicable, may require updates to reflect the new PI. Please contact the ORPA unfunded agreements team for more information.
PI Absence/Reduction of Effort
Prior sponsor approval is required when a PI or other NIH defined Key Personnel, are or will be absent from a project for three months or more, or if they reduce their level of committed effort by 25% or more from the awarded level. Note, For mentored NIH K awards mandating an effort requirement, a reduction in effort cannot be requested. For more information, contact your ORPA RA
Sponsor’s prior approval is required when a PI intends to transfer their grant to another institution. To begin the transfer process, PIs should notify their sponsor’s scientific counterpart as soon as the decision to transfer the award has been agreed upon. If the sponsor supports the grant transfer, the PI should begin working with the ORPA RA, ORACS, their Department Chair and Administrative Support Staff to prepare the required transfer documents (i.e. relinquishing statement). For the transfer of NIH grants, the University of Rochester Statement Relinquishing Interests and Rights in a Sponsored Project Form must be completed and submitted to ORPA. This form will be used by ORPA to complete the relinquishment in eRA Commons. The relinquishment is not final until a revised NIH Notice of Award is received approving the relinquishment.
Existing unfunded agreements (DUA and MTA), when applicable, may require updated agreements to reflect the new Institution when a PI transfers. Please contact the ORPA unfunded agreements team for more information.
For helpful information on other transfer considerations please reference the ORPA Guidance for Principal Investigators and Administrators when a PI is Leaving the University.
Change in Scope
A change in scope is defined as an activity whereby the objectives or specific aims identified in the approved grant application are significantly changed by the recipient after award ( i.e. human subjects and/or animal use not described in the original proposal; the delegation of a significant portion of the scope of work to a subrecipient; involvement of an international entity; significant rebudgeting, etc.). Prior approval is required for a change in scope to be allowable under an award. Contact your ORPA RA for assistance
Generally, under Expanded Authorities, prior approval for rebudgeting on federal awards is not needed. However, rebudgeting of 25% or greater between budget line items. (i.e. purchase of an unplanned piece of capital equipment, previously unplanned foreign travel, new involvement by a subrecipient) could be considered a change in scope and may require prior approval. For awards other than federal, please refer to your award regarding rebudgeting guidelines.
Change of Data Sharing Managment Plan (DMSP)
Prior sponsor approval is required when a change of DMSP for a funded award is necessary. ORPA can submit the request for prior approval upon receipt of certain required documents supporting the change. Documents needed may include a justification for the change, budget documents if the revised DMSP impacts the budget, and a Revised DMSP. In most cases, prior approval for a change of DMSP on an NIH grant can be requested via the eRA Commons Prior Approval Module. A completed NIH Prior Approval for Change of DMSP form must be submitted to ORPA to initiate the request. Please contact your ORPA RA for further information. Existing unfunded agreements (DUA and MTA), when applicable, may require updates to reflect the new DMSP. Please contact the ORPA unfunded agreements team for more information.