Prior Approvals for Post-Award Grant Actions

Purpose

To change a project or budget after an award is made when NIAID requires approval.

Procedure

Under expanded authorities PIs can perform a range of grant actions without Grants Management Program (GMP) approval; however, others require prior approval from NIAID.

The following actions require prior approval from GMP:

• Change in scope, including significant rebudgeting. Get details at What Constitutes a Change in Scope? in the NIH Grant Cycle: Application to Renewal.
• Preaward costs charged more than 90 days before the projected start date of a new or renewal award.
  • Prior approval is not required for charging preaward costs before the start date of a noncompeting grant.
• Change of organization (e.g., transfer from one organization to another).
• Changes in status of key personnel. This includes cases that involve the following:
  • The PI or any key personnel listed on the Notice of Award withdraw from the project entirely.
  • The PI or any key personnel are absent from the project during a continuous period of three months or more.
  • Time devoted to the project is reduced by 25 percent or more from the level approved at the time of award.
• Change in grantee organizational status (change of institution, successor-in-interest, name, merger).
• Addition of foreign component to a domestic grant.
• Deviation from terms of award including restrictions reflected on the Notice of Award.
• Carryover of unobligated balances if not authorized on the Notice of Award.
• Second no-cost extension or an extension greater than 12 months. For more information, read the No-Cost Extension SOP.
• Equipment purchase over $25,000 per unit if it represents a change of scope.
• Retention of grant salary and fringe benefit funds when a person receives a K award.
• Alterations and renovations:
  • Rebudgeting more than 25 percent of a budget period's total approved budget into alterations and renovations costs.
  • If rebudgeting would not meet the 25 percent threshold but would result in a change in scope.
  • Any alterations and renovations cost for a foreign grant.
  • Any single alterations and renovations project exceeding $300,000.
• Rebudgeting of amounts from trainee costs to other budget categories.
• Capital expenditures (construction, acquisition of land or building).
• Need for additional NIH funds (follow approval instructions in the Administrative Supplements to Grants and Cooperative Agreements SOP).
• Transfer of funds between construction and non-construction work.

Principal Investigators

• Get prior approval from your grants management specialist.
• You must send requests to NIAID within 30 days of the planned use of funds. If you fail to request prior approval or spend grant funds without written approval of GMP, NIAID may audit or terminate your award or not allow some costs.
• Your institutional business official can submit a prior approval request by email or letter. You don't sign letters, but you must have a signature assurance on file.
  • Email requests should go to the grants management specialist and include the following:
    • Grant number in the subject line.
    • PI’s name, title, organization, telephone and fax number, and email address.
    • Authorized business official’s name and title, telephone and fax number, and email address.
    • Description of justification for the proposed change.

Grants Management Specialists

• Do the following within five working days of receiving a prior approval request:
• Review the request and determine if the proposed change is allowed.
• Seek guidance from the appropriate division coordinator when required (e.g., if disapproving a request).
• Contact program staff to obtain concurrence. Though program staff review these requests, only GMP can approve them.
• Issue a revised award Notice of Award when required, or email the PI and institutional business official of the approval or disapproval of the request.
  • If disapproving a request that the grantee may appeal, issue the disapproval in a letter on NIH letterhead signed by the GMP division coordinator and program officer. Do not send an email.
• Read GMP's Prior Approval SOP for more information.

Contacts

See Grants Management Program Contacts for the appropriate GMP specialist.

If you have knowledge to share or want more information on this topic, email deaweb@niaid.nih.gov with the title of this page or its URL and your question or comment. Thanks for helping us clarify and expand our knowledge base.

Links

Carryover Requests SOP

Expanded Authorities or Federal Demonstration Partnership SOP

January 6, 2000, NIH Guide notice, Notice on email prior approvals

NIH grants policy statement, prior approval requirements

Some Actions Require Our Approval in the NIH Grant Cycle: Application to Renewal