• Sponsor, SPA, and unit approvals
• Purchasing equipment not in original budget
• Rebudgeting
• Uncollectable costs

Note: Some agencies, specifically NIH and NSF, require approval requests to be sent electronically.

In general, any substantial deviation from the agreed-upon project probably needs prior approval from the sponsor. Check the Notice of Grant Award or contract, the sponsor's policy guidelines, or the SPA grant administrator if questions arise.
 
While the project is being conducted, several occasions will arise when it is necessary to obtain the sponsor's approval. These include:

• scope of work changes;
• change in PI effort;
• change in PI/key personnel;
• specific financial transactions, including
  • significant rebudgeting,
  • use of program income, and
  • travel
• other specific terms and conditions, and
• transferring a substantial portion of the work

To obtain sponsor approval, the PI must write a letter to the sponsor that includes the information listed below. The request must then be signed by the department head and forwarded to the SPA grant administrator.

Electronic prior approvals:


The PI must compose the request. Although departmental staff may assist, PIs must transmit these from their computers in order for their official electronic signatures to appear on the requests.

Attachments: Where additional documentation is necessary for the sponsor to properly evaluate the request, transmit the information electronically whenever possible and practical. This information should be either included in the body of the email request or attached in the form of a text-only file. If hard copy attachments will be sent, write at the bottom of the email: "hard copy attachments to follow."

The PI must then forward the request to the department head or dean (where applicable).

The department head (or dean) must evaluate and approve or return the e-mail requests. Approved requests should be emailed to the grant administrator at SPA.

If the request is appropriate, the grant administrator will endorse it and forward it to the sponsor. This step applies to both paper and electronic requests. The requests may not be acted on until specific approval has been received from the sponsor. Failure to obtain required approvals could result in disallowance of costs or nonpayment by sponsor.

Items to be included in approval requests:

Scope of work changes
• Explain and justify the proposed changes.
• Indicate any changes in funding and/or categorical reallocations.

Change in PI effort
• Decrease of effort (from percent to percent). For many federal sponsors, this decrease must be more than 25 percent of proposed effort.
• What rebudgeting might occur and its impact on the project.
• Duration of change.
• Justification of need for change and its overall impact on the project.

Change in PI/key personnel
• CV for proposed PI/key personnel.
• Other support information.
• Justification of need for change and its overall impact on the project.



Use of program income

Federal sponsors address program income via OMB Circular A-110 and the applicable Code of Federal Regulations. Additionally, federal sponsors may also provide guidance in their specific policy guidelines which does not necessitate prior approval request unless the alternative provided is not the desired method for handling program income. In the case of non-federal sponsors, if the sponsor proposal guidelines, award terms, and/or policy guidelines remain silent in program income, any income generated under awarded projects will be treated as non-reportable and will be handled by External Sales Office and/or Office of Technology Commercialization, dependent on nature/type of income. Notification to a non-federal sponsor is required only if their terms require such notification.
 
Travel
The department must get all necessary approvals before the start date of the travel. Refer to the University financial policy and procedures on Traveling on University Business for more information. The department must retain records documenting this approval.
 
Other specific terms and conditions
Many sponsored project agreements require PIs to obtain the sponsor's written approval before specific changes may be made in the project. Approval requirements customarily noted in the Notice of Grant/Contract Award include:

• unanticipated subcontracts,
• substantial budgetary changes,
• building alterations or renovations, and
• patient care costs.

Expanded authority
In an effort to save time and paperwork, several federal agencies have granted SPA the authority to make certain specific decisions regarding sponsored projects. Authority has been generally granted to allow SPA to authorize:
• no-cost extensions of up to 12 months
• rebudgeting
• program income use alternatives (except for the 'matching' alternative. See the University academic policy on Managing Program Income Earned on Sponsored Projects, for details).

• are not enforced by SPA,
• can only be more restrictive than sponsor and SPA approval requirements.

Purchasing equipment that was not listed in the original budget

Certified Approvers (CAs) are responsible for making sure that this equipment is allowable, allocable, and reasonable on the project. SPA is not involved in approving requests for equipment purchases not included in the approved budget, also known as IPAS, unless sponsor approval is necessary.

Some sponsors require prior approval for any changes in the budget. To determine whether prior approval is required, review the award notice or contract and sponsor policy. Note that if the equipment purchase reflects a change in workscope, you must contact SPA to determine whether prior approval is necessary

For audit purposes, it is important to adequately document the reasons and approval process for the purchase. Include in the comment box on the purchase order the following information:

• An indication of the benefit to the project for each item. If a PI wants to purchase general purpose equipment, documentation must justify how the purchase advances the objectives of the grant.

• A statement that suitable equipment is not available elsewhere at the University for use on this project.

• Proration of the costs based on usage of the equipment on each project, if you plan to charge the equipment on more than one account.

• If you need a new equipment object code, email a request to process an EB to your grant administrator, including amounts and objects.

• If the equipment object code already exists on the account, process an ET to rebudget both the equipment funds and applicable indirect cost.

Rebudgeting
Rebudgeting is the shifting or rebudgeting among budget categories. Sponsors may have limits for how much funds can be shifted or rebudgeted among budget categories, which budget categories can be rebudgeted, or not allow rebudgeting.

To request a new object code, send the document to SPA requesting that the object code be set up and identify where the funds should come from. The Grant Administrator will establish the budget line.

Before moving funds from one budget line to another, check the sponsor's policy to determine any established limits or restrictions. For some sponsors, SPA may have the authority to approve certain rebudgeting requests. In general:

Approval from the sponsor is not required:
For rebudgeting in unrestricted categories, use the NBUD form.
 
Approval from the sponsor is required:
The sponsor's approval is required if:
• the rebudgeting indicates a change in the scope of the project,
• the rebudgeting takes place between restricted categories,

 
For information on the sponsor's limitations and requirements, consult the sponsor's policy guide. For federal sponsors, also consult Circulars OMB A-21 and A-110.
 
Rebudgeting approval process:
• The PI must write a letter addressed to the sponsor. This letter must identify the reallocations and justify the proposed changes.
• The letter must be signed be the PI and department head (or academic designee).
• The letter must be forwarded to the appropriate SPA grant administrator for review and institutional endorsement.
• SPA will forward the letter to the sponsor.
• When written approval is sent by the sponsor, the NBUD and a copy of the letter must be sent to SPA for processing.