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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. Please contact Sponsored Projects Services (SPS) 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
The criteria below determine whether you are attempting significant changes to your project. All project changes that meet any of the requirements below require formal requests and approval from the sponsor. Requests for changes to the project must be countersigned by an institutional representative from SPS before the investigator contacts sponsor.
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 grants awarded under the terms of the Federal Demonstration Partnership (FDP), the investigator is not limited by the categorical breakout of the budget, unless:
- 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 FDP 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. Please contact Sponsored Projects Services with any questions
- See particular sponsor terms and conditions for non-FDP sponsored projects
See the Budget Categories page for understanding how to rebudget administrative costs on federal accounts.
Each time the project director, program director, or principal investigator significantly change their participation level in a particular project, the University must notify the awarding agency as soon as such information is known. Significant change in level of effort is defined as:
- Relinquishing active direction of the project permanently
- Relinquishing active direction of the project for a continuous period of more than three months
- A 25% reduction in time devoted to the project
- For complete change of principal investigator see the Award Transfer page
Since approval of a project has, to some extent, been based on the participation and/or qualifications of the named Key Personnel, the awarding agency requires notification and the option to approve or deny alternate plans for conducting the activity.
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, by contracting or any other means. 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.
Some sponsors do not require their approval before subcontracting to a third party. For those sponsors, the University requires sponsor notification rather than sponsor approval. An award based on a proposed budget with a line item for the named subcontractor constitutes acceptable documentation of sponsor notification. Please refer to the Subaward Initiation and Setup page for initiating a subcontract.
Approval of the sponsoring agency is required for changes in the effective date, termination date, and due date for deliverables or technical reports. See provisions for institutional approval of Advance Account spending (PreAward costs) and no-cost extensions below for grants awarded under the Federal Demonstration Partnership.
If you want to change the effective start date of a sponsored project you need to secure sponsor approval.
Many Federal grants are awarded under the terms of the Federal Demonstration Partnership (FDP). Contact Sponsored Projects Services (SPS) if you are unsure whether or not your project is awarded under the FDP. The terms of the FDP 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 SPS 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 requires sponsor approval.
For most grants awarded under the Federal Demonstration Partnership, 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 for an FDP grant by writing a letter to the director of SPS. The letter should indicate:
- 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 director will notify the sponsor of the new termination date and repeat the supporting justification provided in the request letter.