Throwback Blog: Prior Approvals and Expanded Authorities

Prior Approvals

All award activities and expenditures require prior agency approval. Prior approval may be granted in the Notice of Award (NOA) when a proposal is funded. For example, equipment and other capital expenditures generally require prior agency approval. By including an equipment purchase in the budget and budget justification, we receive written approval to purchase the equipment when awarded unless otherwise noted in the award terms and conditions.

There are, however, times when changes to project activities and expenditures need to be made during the life of the funded project. For example, when an investigator wants to acquire equipment not included in the original approved budget. The PI may need written agency approval to make this change.

Prior approval requirements we are most familiar with include:

  • Changes in the scope or objective of the project
  • Changes in the approved budget
  • Changes in key personnel
  • Changes in the total approved cost-sharing amount
  • Disengagement of the PI from the project for more than three months or a 25% reduction in time
  • Rebudgeting of funds budgeted for participant support (trainee costs)
  • Adding subawards not proposed in the initial application

Expanded Authorities

There are a limited number of post-award actions that typically require prior sponsor approval for which approval authorities have been ‘expanded’ to the grantee. These actions are commonly referred to as ‘Expanded Authorities’ and are for changes necessary to complete the project within the original scope of work and budget. They generally apply to Federal research assistance awards (i.e., grants and cooperative agreements), not contracts.

Under Expanded Authorities, sponsoring agencies may waive certain prior approval requirements and provide authority for a recipient to undertake activities and expenditures without prior approval.

Areas in which federal awarding agencies have the option to waive prior approvals are outlined in Uniform Guidance. These include:

2 CFR & 200.308(g)

(1) Incur project costs 90 calendar days before the federal award is made.
  • Pre-award costs are at the recipient’s risk and must be necessary, not just for convenience. For example, the purchase of animals in advance so they are in place to begin IACUC-approved research on the start date.
  • At CSU, an ‘At-Risk’ Spending Request (advance start or continuation spending) must be in place before any expenditures. If an award is not received, the department and/or college assume responsibility for any costs incurred.
(2) Initiate a one-time extension of the period of performance (aka no-cost extension) by up to 12 months beyond the original award end date.
  • The additional time must be necessary to complete the scope of work and not just for convenience. For example, an equipment purchase was delayed, which delayed the project’s activities.
  • To request an NCE, complete the ‘No Cost Extension Request’ form well in advance. CSU must notify the sponsor at least 10 calendar days before the end of the period of performance. Provide valid justification for the extension and the new end date (up to 12 months from the current one). For NSF awards, refer to the guidance, “NSF No-Cost Extension in Research.gov.”
(3) Carry forward (aka carryover) unobligated balances to subsequent periods of performance.
  • Always check the award terms and conditions for restrictions on carry forward.
  • Restrictions on carry-forward should be noted in the KR Award General Comments section, displayed in the RPS Comments area.

2 CFR & 200.308(i)

Transfer of funds among direct cost categories (unless the transfer impacts any of the prior approval cost categories listed above).
  • Rebudgeting authority is generally limited to 10% of the total approval budget, including cost-share.

Prior Approval Matrix – Caution!

A Prior Approval Matrix has been hosted on the NSF website for many years and has been referenced by many federal agencies, but it has undergone significant changes. Due to updates to Uniform Guidance, the current NSF Prior Approval Matrix is available and applicable only for NSF grants that were awarded after October 1, 2024.

The legacy Prior Approval Matrix from November 2020 applies to awards made before Oct 1, 2024, that have not received modifications or supplements that supersede the previous terms and conditions.

While the matrix has been a helpful tool, it is vital to remember that the specific terms and conditions of an award will always supersede the Prior Approval Matrix.

Conclusion

Not all agencies exercise their right to waive prior approvals. For those agencies that have, they may not waive all prior approvals or waive them for every program. Therefore, checking the agency’s policies and specific program terms and conditions is important to see if these authorities have been granted. If an agency/program grants expanded authorities, they are automatically applied unless overridden in the NOA. When in doubt, begin with the award terms and conditions, working back to program and agency-specific terms.

Original Blog post from 2021 by Tricia Callahan, Senior Research Education and Information Officer, Office of Sponsored Programs; Updates by the OSP Training and Information Team, Office of Sponsored Programs