Given the nature of research and the difficulty of making precise plans in advance for any undertaking, it is often necessary to revise budgets and even to change significant aspects of a project after the award has been made. However, changes to the terms of an award always require approval. Two basic questions must be answered when a PI is considering a change.

1. Who must provide the approval, the sponsor or the University?
2. Does the sponsor require that the change be approved in writing?

While the terms and conditions of the award are the definitive source of answers to these questions, the information in this section provides some general guidelines.

General Procedures

Check the ORS New Award Notification Memo or your Award Management Checklist if you prepared one and the terms and conditions of your award to determine if the change must be approved by the sponsor in advance or, alternatively, if it can be approved by the University in accordance with criteria established by the sponsor.

If the request can be handled in-house, the request from the PI or PD will be reviewed and approved by ORS. The approved request will be sent to the PI and to OSP so the official record can be updated.

If the change must be approved by the sponsor, the PI's letter of request must be sent first to ORS for review, approval, and signature before it is forwarded to the sponsor. When the request is approved by the sponsor, ORS will send copies of the approval notification to the PI and to OSP.

Non-federal Awards

It is difficult to generalize about changes on non-federal awards. If there is little detail provided in the terms and conditions, it may be necessary for ORS to contact the sponsor.

Federal Awards

In federal awards the regulations for making changes to an award are usually well defined. The following changes must always be approved by the federal sponsoring agency:

• changes in the scope or objectives of the project
• the absence for more than three months or a 25% or more reduction in time devoted to the project by the PD or PI
• change of PI
• change in key personnel specified in the application or award
• transfer of funds allotted for training allowances (direct payment to trainees) to other categories of expense

The following changes are more likely to fall under the authority of the University to approve (expanded authority); however, the terms and conditions of the award must be consulted:

• no-cost extensions
• rebudgeting of funds
• purchasing equipment not identified in the award
• carry-over of funds
• addition of new subrecipients under an award unless the subrecipient is a foreign institution or a corporation