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Project Changes

When a grant or contract is awarded in response to a proposal, the sponsor expects the project will be carried out in accordance with the proposed scope of work and the approved budget. Since the course of research is often uncertain and circumstances can change, provisions to manage project changes are necessary. When this is the case, requirements to obtain sponsor prior approval vary widely: some sponsors are very restrictive; others allow wide latitude for changes that benefit the project.

Principal Investigators (PIs) are responsible for maintaining written justification that changes are scientifically necessary and appropriate using the following guidelines:

  • Correlate expenditure to successful completion of the project
  • Justify project changes in terms of the science or programmatic needs
  • Systematically maintain justifications in the file

To determine whether a proposed change is permissible:

  • Review the terms of the specific award notice;
  • Review sponsor general terms and conditions and any referenced regulations, laws, guidelines and agreement manuals;
  • Ensure changes are consistent with project objectives and statement of work, and document this information;
  • Review Agency requirements (see sample Prior Approval Matrix);
  • Review Office of Management and Budget (OMB) Circular 2 CFR Part 200: Cost Principles for Educational Institutions: Section J;
  • Review University of Oregon (UO) policies and procedures to ensure the proposed transaction is consistent with UO policies; and
  • Discuss the proposed change(s) with the Sponsored Projects Services (SPS).

SPS works with the PI and the sponsor to implement any changes in the project which require UO and sponsor approval (such as changes in scope of the project, key personnel, budget, and other modifications of award terms and conditions).  Requests for changes should be discussed with the Post Award Sponsored Projects Administrator (SPA) and may need to be approved and signed by SPS before submission to the sponsor.  Certain significant changes may also require the review and approval by the department chair and/or dean of the school.

Project changes are of three basic types: programmatic, budgetary and administrative:

Programmatic changes are necessary when the PI determines that the direction of the project must change based on the results obtained to date. For some sponsors, changes in the model, the physiological or pathological condition being studied may require sponsor approval. Also, adding human subject research or animal research to a project is a programmatic change and may require sponsor notification as well as Institutional Review Board (IRB) and or Institutional Animal Care and Use Committee (IACUC) approval.

Budget changes are necessary when the PI determines that expenditures are required for unanticipated items not included in the proposal budget (e.g., the purchase of equipment not originally needed for the project, or an unexpected trip that increases the amount spent for travel). Generally, budget changes involve moving funds from one budget category to another, without increasing the total amount of the award. Occasionally, however, a need arises that can be met only with increased funding and thus usually requires submission of a proposal for supplemental funds. Such requests are handled differently from requests to rebudget funds. See Budget Revisions for additional information.

Administrative changes, the third general category of project changes, include but are not limited to:

  • Changes in scope of work (see Programmatic Changes above and Expanded Authorities or Waiver of Authorities below)
  • Expenditure of funds before receipt of the formal award (pre-award costs)
  • Extension of the project period (no-cost extension)
  • Changes in the effort of the PI or other key personnel named in a notice of award
  • Carryover of unexpended funds from one budget period to another

Sponsored Projects Services
August 20 2008