Prior Approval Process

							Prior Approval Process

Definition:
The term “prior approval” refers to the sponsor requirement for PI to obtain written
institutional or agency approval for specified postaward changes in the approved project
or budget. If the award in question is from a federal agency, general guidance is
received in both OMB Circulars A-110 and A-21. However, individual agency guidelines
must be reviewed to determine whether correspondence must be sent to the agency or
whether an institutional prior approval is permitted. If the sponsor is not a federal
agency, unique terms may apply and require careful review. Whether internal or
external approval is needed, accurate and complete documentation is required.

Key Changes Requiring Agency Approval:
    Change in Scope
    Change in PI
    Need for Additional Funds
    Change in Grantee Institution
    Decision to Subcontract Substantive Portion of the Research

Most Common Postaward Modifications Needing Prior Approval
   No-Cost Extensions of the final budget period
   Change in Key Personnel
   Rebudgeting of Funds
   Carryover of Funds from one budget period to another

Prior Approvals Granted by the Institution
Washington University Research Office employs a Project Activation Request Form for
the most common internally delegated prior approvals. Requests transmitted by this
form include pre-award costs, advance expenditure (start date arrives with no award in
hand), no-cost extensions, and the justified expenditure of administrative and clerical
costs. The form used expedites University policy of obtaining complete justification of
the request, departmental approval and guarantee accounts for at-risk expenditures.

Prior Approvals Granted by the Agency
If award terms stipulate that agency approval is required for the postaward modification
requested, the PI must write a letter or e-mail of justification to the appropriate program
officer and/or grants management official. The authorized institutional official may co-
sign the letter or forward the e-mail, depending on the preferences of the agency.
National Science Foundation requires that PIs process such requests through the
Fastlane system. PIs or department staff may consult the policies and award terms of
the sponsoring agency or contact RO staff to determine the appropriate action.

Project Activation Form
http://wuro.wustl.edu/PA%20Form%20_1107.pdf
FDP Prior Approval Matrix
http://www.nsf.gov/pubs/fdp/fdpmatrix.xls
NIH Prior Approval Policy
http://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part7.htm#_Toc54600129