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Award Management - Prior Approvals

Although many sponsored awards allow flexibility in areas such as rebudgeting, carryforward of unobligated balances from year to year, and pre-award costs, sponsors expect expenditures to be reasonably consistent with the proposed scope of work and budget.  Many federal agencies have chosen to delegate authority to the University for rebudgeting, pre-award costs, single no-cost extensions, etc.  The Department and PI should refer to the sponsored award terms to determine the authorizations that apply to each award.
Sponsors often require PIs to request prior approval for significant changes that affect the scope of work and budget. Please remember that all requests to a sponsor should be coordinated through ORPA.

ORPA Prior Approval and Other Requirements Matrix contains prior approval requirements for multiple federal government agencies.

PI Transfer/Absence/Reduction of Effort
Advanced written sponsor approval is required when a PI intends to transfer to another institution, plans to be absent from the project for three months or more, or reduce his or her level of effort by 25% or more from the awarded level. 

Circular A-110 and 2 CFR 200 Uniform Guidance also require prior approvals from the sponsor in the following circumstances:

  • change in the scope or the objective of the project or program (even if there is no associated budget revision)
  • change in a key person specified in the application or award document
  • need for additional Federal funding
  • transfer of funds allotted for training allowances (direct payment to trainees) to other categories of expense.

Certain sponsor 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 ensure whether the award requires advanced sponsor approval for carryforward of unexpended funds to the next budget period.