Prior Approvals for Post-Award Grant Actions

Purpose

To change a funded project in a way that requires prior approval from NIAID.

Procedure

While PIs can perform a range of grant actions under expanded authorities, they must get prior approval from NIAID for the following things:

• 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 in scope. Get details at What Constitutes a Change in Scope? in the NIH Grant Cycle: Application to Renewal.
• Change of organization (e.g., transfer from one organization to another).
• Change in status of key personnel listed on the Notice of Award. This includes cases that involve the following:
  • PIs who withdraw from the project entirely or leave the project for three or more consecutive months. See the Change of Principal Investigator SOP.
  • Departure of key personnel.
  • Reduction in time devoted to the project 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 a foreign component to a domestic grant.
• Deviation from terms of award or 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.
• Purchase of equipment over $25,000 per unit, if it represents a change of scope.
• Change to alterations and renovations:
  • Rebudgeting more than 25 percent of a budget period's total approved budget into alterations and renovations costs.
  • Rebudgeting that creates a change in scope, even if the amount is less than the 25 percent threshold.
  • Alterations and renovations costs for a foreign grant.
  • Any alterations and renovations project exceeding $300,000.
• Rebudgeting of amounts from trainee costs to other budget categories.
• Rebudgeting of salary and fringe benefits for investigators who receive career development awards.
• Addition of NIH funds. See the Administrative Supplements to Grants and Cooperative Agreements SOP.
• Capital expenditures (construction, acquisition of land or building).
• Transfer of funds between construction and non-construction work.

Read more at Prior-Approval Requirements in the NIH Grants Policy Statement.

Principal Investigators

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

Grants Management Specialists

• Do the following within five working days of receiving a request:
• Confirm receipt of the request by sending a Prior Approval Request -- Initial Reponse email to the grantee.
• Determine if the proposed change is allowed.
• Seek guidance from the appropriate division coordinator when required (e.g., if disapproving a request).
• Get concurrence from program staff, keeping in mind that only GMP can approve or disapprove the request.
• If you approve a request, email the PI and institutional business official. Issue a revised Notice of Award when required by GMP.
• It you do not approve a request, send aDisapproval Letter signed by the GMP division coordinator and program officer. Do not send email.
• Upload approval and disapproval documents into eGrants.
• 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

NIH grants policy statement, prior approval requirements

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