Given the nature of research and the difficulty of making precise plans in advance for any undertaking, it is often necessary to revise budgets and even to change significant aspects of a project after the award has been made. However, significant changes to an award may require the prior approval of the sponsor. One basic question must be answered when a PI is considering a change.
- Who has the authority to approve the change, the sponsor or the University?
The sponsor’s terms and conditions of the award are the definitive source for the answers to these questions.
The department should work with ORS to determine what the terms and conditions of the award require. Many minor changes may not require the prior approval of the sponsor, but may still require internal documentation for audit purposes.
If the request can be handled in-house, then the department can submit the request from the PI to ORS for review and approval. ORS will send the approval to the PI and to OSP.
If the change must be approved by the sponsor, then the department should send the PI's letter of request to ORS for review, approval, and signature before it is forwarded to the sponsor. When the sponsor returns the approved request, ORS will send copies of the approval notification to the PI and to OSP.
It is difficult to generalize about changes on non-federal awards. Whether or not changes require sponsor approval must be determined on a case by case basis. If there is little detail provided in the terms and conditions, it may be necessary for ORS to contact the sponsor to find out if the changes need sponsor approval or not.
In federal awards the regulations for making changes to an award are usually well defined. The following changes almost always must receive the prior approval by the federal sponsoring agency before the change takes place:
- changes in the scope or objectives of the project
- the disengagement of the PI for more than three months or a 25% or more reduction in time devoted to the project by the PI
- changes in key personnel (including PI and Co-PIs )specified in the application or award
- transfer of funds allotted for training allowances (participant support costs) to other budget categories
- issuing a new subaward
- changes in the approved cost-sharing or matching amounts,
- additional federal funds are needed.
The following changes are more likely to fall under the authority of the University to approve; however, these changes may be restricted under the terms and conditions of a specific award:
- first time no-cost extensions
- rebudgeting of funds
- purchasing equipment not identified in the awarded budget
- carry-over of funds from one budget period to the next.