Prior Approvals for Federally Funded Research Grants Subject to the Research Terms and Conditions

APRIL 20, 2018

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I. Purpose of Policy

As a recipient of federal funding, the University must comply with 2 CFR, section 200, OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D §200.407, Prior Written Approval. For federally funded research agreements, these requirements have been amended and implemented through the Research Terms and Conditions (RTC).

The purpose of this policy is to provide guidance for obtaining prior approval of certain post-award changes to federally funded research agreements that incorporate the RTC.

Changes to the terms and conditions of any award not covered by this policy are subject to the terms and conditions of the relevant award. Contact ORA for guidance prior to implementing any such change.

II. Scope of this Policy

This Policy is applicable to all Principal Investigators and other University personnel involved in administering federally funded research awards subject to the RTC.

III. Stement of Policy

It is Brandeis University policy that Prior Written Approval of any change to the terms and conditions of an award subject to the RTC requires that ORA approve (with the additional approval of the sponsoring agency when necessary) any such change in writing, prior to its implementation.

IV. Roles and Responsibilities

a. University Institutional Prior Approval System (IPAS) and Expanded Authorities for the Management of Federal Grants Subject to the Research Terms and Conditions

A PI must request prior approval for certain changes to the terms and conditions of awards covered under the RTC from the Office of Research Administration (ORA). ORA will determine whether any such request for prior approval can be granted institutionally or must be approved by the sponsor. These changes include the following:

Pre-Award Costs

o To create a sponsored project for the purpose of incurring pre-award costs up to a maximum of 90 calendar days prior to award start date.

No-Cost Extension

o To initiate the first extension of the award expiration date for a period up to 12 months long. The sponsor must be notified of the extension prior to the original termination date. This extension may not be exercised solely for the purpose of using any unobligated balance.

Adding Scientific or Special Purpose Equipment

o To re-budget funds for the purchase of scientific or special-purpose equipment not identified in the original sponsor approved budget, general-purpose equipment is not allowable unless used solely or primarily for the objectives of the sponsored project and if the cost supports the activity that is directly related to the special purpose or circumstance of the sponsored agreement.

Approval Required from the Sponsoring Agency

o The PI of a Federally-sponsored project is required to report major deviations (as outlined below) from budget and program plans. The PI should work with ORA, following IPAS procedures, to request prior approval directly from Federal awarding agencies for any of the following program or budget-related reasons:

  • Change in the scope or the objectives of the project or program.
  • Change in the PI and/or key personnel (the definition of key personnel may vary by sponsoring agency) or in project effort (absence for more than three months or a 25% reduction in time devoted to the project).
  • Transfer of funds allotted for trainee expenses (direct payment to trainees: stipend, tuition, fees) to other categories of expense.
  • Subawards, transfers or subcontracting a substantive portion of work, unless described in the application and funded in the approved award.
  • Budgeting of pre-award costs to be incurred more than 90 days prior to award.
  • Other expenses, if not waived by a particular agency in the notice of award (i.e., foreign travel, carryforward of funds from one budget period to the next, re-budgeting of trainee allowances or participant costs, alterations and renovations in excess of $25,000, adjustment of cost sharing commitment).

b. Making a Request under the Institutional Prior Approval System (IPAS)

All requests for prior approvals under this policy must be made on an IPAS Request Form.

Approval for any changes must be received prior to implementing those changes. Generally, requests for approval of changes that have already occurred will be reviewed but cannot be approved by ORA.

  • ORA should be consulted before submitting the IPAS.
  • The signatures of the PI and ORA are required to complete the IPAS approval.
  • The PI should complete and sign the attached form before submitting it to ORA for final approval.
  • Each request must include a well-detailed justification explaining the reason for a deviation from the original, approved budget and/or work plan.
  • Each request will be reviewed for appropriateness in relation to the objectives of the project and for compliance with the regulations, policies and procedures of both the University and the sponsor.
  • Once an IPAS request has been approved, Sponsored Programs Accounting (SPA) will be notified and the appropriate changes will made to the financial system.
  • PIs should refer to specific terms and conditions from the awarding sponsor for details on budget restrictions and/or post-award changes.

c. Making a Request to the Awarding Sponsor Agency

Those changes requiring approval from the awarding sponsor should be described on the IPAS Request Form. ORA will review each request and prepare the appropriate communication to the sponsor, which may be a direct communication with a sponsoring agency official or a request submitted through the appropriate sponsoring agency‘s electronic system Note that only ORA signatories are authorized to deal with sponsoring agency personnel with respect to changes in award terms and conditions.

V. Related Resources