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Each award should be treated separately. The general rules and guidelines below are intended to augment the specific terms and conditions of individual awards. The criteria below determine whether you may be attempting significant changes to your project. These project changes below may require formal requests and approval from the sponsor. Please contact Sponsored Projects & Contracting Services (SPCS) if you have a question about whether a change to your project requires sponsor notification and/or approval.
Procedure for Requesting Sponsor Approval for Project Changes
Requests for changes to an existing project should be prepared by the investigator and business team, and countersigned via email or digital signature by an institutional representative from Sponsored Projects Postaward.
If the project is a unilateral grant, sponsor approval will go directly to postaward for processing. If the project is a bilateral contract, a contract modification may be necessary and the contracting office will be involved to complete the change.
The budget is an estimate of the spending plan for the project. Often, actual spending varies from the categorical budget breakout. The terms of your award will dictate how much the actual project expenditures may vary from the cost categories of the award budget.
For federal grants awarded under the terms of the Research Terms and Conditions/Federal Demonstration Partnership (FDP), many rebudgeting authorities are granted to the institution so long as the rebudgeting is necessary to complete the scope of the project. However, these conditions may indicate a change in scope and need for prior approval:
- Significant alteration to the scope such as changes to objectives, aims, methodology, etc.
- Transferring a significant part of the research outside the University (usually in the form of a subcontract)
- The general guidance on project changes is that a deviation in a budget category of more than 25% of the total award indicates a change in the scope or objectives of a project.
- Equipment purchases may require sponsor approval.
See particular sponsor terms and conditions for non-FDP sponsored projects
Each time the a principal or co-investigator named as Key Personnel significantly change their participation level in a particular project, the University must notify the awarding agency as soon as such information is known. Example:
- PI or Co-PI leaving the project and/or being replaced by alternate investigators. An administrative change proposal should be routed to institutionally capture approvals for the changes, and then the prior approval request can be submitted to the sponsor. For complete change of principal investigator see the Award Transfer page.
- Absence from the project for a continuous period of more than three months.
- A 25% reduction in effort budgeted to the project (25% of the originally proposed effort. Ex. a 10% to 5% change is a 50% reduction in effort and needs approval).
Scope or Objectives
Approval from the awarding agency is required for a proposed change in the statement of work under study or the specific aims of the project stated in the proposal or agreed modifications. Examples of common changes requiring sponsor approval include, but are not limited to:
- Substitution of one animal model for another
- Any change from the approved use of animals or human subjects
- Shifting the emphasis of the research from one disease to another
If you are unsure whether particular changes to the scope of your sponsored project require sponsor approval contact your program office. Protect yourself in writing.
Most sponsors require their prior approval before the University can transfer substantive programmatic work to a third party (subawarding). Sponsors award projects to the University and expect the University to perform the programmatic work. Generally, an award based on a proposal budget with a line item for the named subcontractor constitutes documentation of sponsor approval.
However, some sponsors such as NIH do not require their approval before subcontracting to a third party so long as the subcontract does not indicate a change in scope.
Please refer to the Subaward Initiation and Setup page for initiating a subcontract.
If you want to change the effective start date of a sponsored project you need to secure sponsor approval.
However, many Federal grants are awarded under the terms of the Research Terms and Conditions/Federal Demonstration Partnership (FDP). These terms allow the University to incur costs up to ninety (90) days before the effective date of the project.
The costs to be incurred must be necessary for the conduct of the project and must be allowable under the potential award. The department assumes responsibility for covering the obligations and expenditures in the event that the award does not come through. To set up an Advance Account, submit the Advance Account & Backstopping Form to SPCS with a copy of the associated fully-signed Proposal Routing Sheet.
Extending the termination date of the project or the due date for deliverables or technical reports generally requires sponsor approval.
Contracts (Bilateral agreements):
- Contracts usually require a contract modification signed by both parties agreeing to the change. The request for extension can be transmitted through sponsored projects, or the PI/unit can correspond with the contracting office to initiate the modification.
Grants (Unilateral agreements):
- However, for many unilateral grants awarded under the Research Terms and Conditions/Federal Demonstration Partnership (FDP), the University has the authority to extend the termination date one time for a period up to one year beyond the original termination date. The principal investigator requests a no-cost extension by emailing their post award team. The email should contain:
- The new termination date
- Provide justification for requesting the extension
- Extending the termination date in order to spend remaining funds is not an acceptable justification
- The post award team will notify the sponsor of the new termination date and repeat the supporting justification provided in the request letter.
- If sponsor approval is required for the grant no cost extension, postaward will transmit the request to the sponsor.
The principal investigator and administering unit are responsible for ensuring Conflict of Interest obligations for the project are fulfilled prior to requesting the extension.