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Prior Approvals Requirements

Ongoing communication between the university and the sponsor is a critical component of sound fiscal management. Such conditions as re-budgeting, change of PI status or effort, no-cost extensions, or considerations related to the scope of the project warrant official written communication from the Office of Sponsored Programs (OSP) to the Sponsor’s Grants Administrator or Contracting Officer.  PIs can discuss changes with their technical officer but the official notification comes from OSP.

For your federal sponsors a Prior Approval Matrix is available as a guide.  However, please remember that this is just a guide, and your individual award terms may be different.

The federal government reduced some required prior approvals in an effort to streamline the grants management process by issuing “expanded authorities”.  Expanded authority allows the institution to approve certain changes.  For example, a researcher may wish to extend the time allotted for performing the work without requesting any additional funds (called a “no-cost extension”). In some cases, prior approval of the funding agency is required for this action; in some cases it can be done without this explicit approval by “expanded authority.”   Expanded authority still requires UMBC/OSP to review, document approval of the changes and inform the sponsor of the action.

DOCUMENTATION

Prior approvals must be in writing from the Grant or Contract Officer, and UMBC. E-mail is one way to record this approval, particularly for grants. Contracts may require an actual signature. In any event, prior approval requests normally are initiated by OSP.  If you have something you believe requires prior approval contact your administrator or OSP contact person. 

Without documentation of this approval, expenditures for such costs will be unallowable, even if you have verbal authorization from the sponsor. It’s not unusual for this type of expenditure to be reviewed in a post-award or closeout audit, which can occur years after the expenditure took place. Without the documentation in the file, it is likely that such costs will be disallowed, and will have to be paid with department funds.

While it is important to remain in communication with the technical officer when such conditions warrant, these kinds of pre-approvals must come from the sponsor’s Grant or Contracting Officer.

Suggestion: In most cases you would want to make sure your technical officer agrees with the change first from a scientific standpoint; then you can send to OSP for communication to the sponsor’s Grant or Contracting Officer.