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Expanded Authorities/Waiver of Prior Approval Requirements

Federal regulations require prior approval from an awarding agency for a variety of project changes. While the federal government's Office of Management and Budget (OMB) has reduced the number of required prior approvals in an effort to streamline the grants management process, a few required prior approvals remain. More detailed information is presented in OMB Circulars:

2 CFR Part 200: Cost Principles for Educational Institutions
A-110: Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education

Many federal agencies have waived cost related prior approvals and permit an institution to decide budget changes under the "expanded authorities." These expanded authorities only apply to certain grants and do not apply to contracts. In addition to the cost related prior approval waiver, in general, the following changes may be permitted without prior agency approval:

  • Pre-award costs up to 90 days prior to award
  • One-time expiration date extension of up to 12 months
  • Carryover of unobligated balances to subsequent funding periods

Certain other changes, however, require prior approval of the awarding agency:

  • Changes in project scope or objective as evidenced by:
    • Change of Principal Investigator (PI) or other key personnel
    • Absence of the PI for more than three months, or a 25 percent reduction in effort spent on the project by the PI or other key personnel
    • Transfer of the performance of substantial programmatic work to a third party
    • Significant rebudgeting, whether or not the particular expenditures require prior approval.
    • Need for additional funds
    • Other changes specifically cited in the award or in agency-specific guidelines

Contact the Post Award Sponsored Projects Administrator (SPA) to determine whether the award falls under Expanded Authorities.

Sponsored Projects Services
August 20 2008