Authorization to Amend a Subaward

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Changes to a scope of work, key personnel, or budget often require sponsor approval. The same approvals apply to changes to a subrecipient’s scope, personnel, or budget. Often when a CSU PI and a subrecipient’s PI decide to make changes, these changes are not communicated to the department or to the OSP, which may result in unapproved activities, unallowed charges, or disputes.

Some changes that often require an amendment to the subaward include:

  • Change in the of scope of work
  • Change of the subrecipient’s PI, key personnel, or their effort
  • Modification or addition to terms and conditions
  • Budget amendments (increase/decrease funding)
  • Addition of carryover funds approved by sponsor
  • Revision of the period of performance
  • Early termination

Many of these actions are triggered automatically by amendment to our prime award, however, if your PI is discussing any of the above changes with a subrecipient mid-project, sponsor approval and amending the subaward may be needed. 

Begin by asking your PI for information describing the requested change. Work with your OSP pre-award team to determine if sponsor approval is needed. Once sponsor approvals are received, or determined not to be needed, the OSP pre-award team will work with the OSP subaward team to determine if an amendment is needed. Even if a change does not require sponsor approval, issuing an amendment to the subrecipient ensures that all parties are aware of the change, which will help to minimize disputes. But like all things in research administration, whether we issue an amendment may depend on the individual circumstances.

If it is determined an amendment is needed, the OSP pre-award team will submit an OSP internal form called an “Authorization to Amend” to the OSP subaward team. The Authorization to Amend provides the details needed to draft the amendment. Once the amendment is fully executed, a copy is provided to the Fiscal Officer and Principal Investigator for department records.

Blog post by Kris Miller, Subaward Administrator, Office of Sponsored Programs