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Under OMB Circular A-110, most federal government funding agencies have delegated prior approval authority to universities for certain post-award actions related to grants and cooperative agreements that were previously reserved for the sponsor.
These “expanded authorities” generally allow universities to authorize pre-award costs up to ninety days in advance of the official start date of the award, carry forward of funds from one budget year to the next budget year in a project cycle, and a single no-cost extension for up to twelve months, among other delegations.
A chart that outlines by federal sponsor the basic prior approvals that universities may authorize has been prepared by the Federal Demonstration Project for ease of reference. To secure a no-cost extension of a project, the sponsor must be notified of the institutional approval at least ten days prior to the expiration date of the award or the delegated prior approval authority is abrogated and sponsor approval has to be obtained.
Note that a significant change in the scope of a project, a significant reduction in committed effort to the project by the principal investigator (generally a decrease of 25% or more) or a significant absence of the principal investigator from the project (90 days or more), and a significant change in budget require prior approval of the sponsor.
Also note that there are deviations among sponsors regarding the extent to which expanded authorities have been delegated to universities; in some cases, particularly DOD agencies, there are key restrictions/limitations to which the Institute must comply.
OSR staff should be consulted well in advance of the effective date of a desired prior approval action to ascertain if the Institute may proceed under expanded authorities or if a request to the sponsor is mandated. In the latter case, OSR staff will work with the investigator to prepare and submit the appropriate request.
There are no expanded authorities under federal contracts. Very few non-government sponsors delegate prior approval authority to an award recipient. Again, in those instances when a principal investigator wishes to pursue an action requiring sponsor prior approval, OSR staff should be consulted well in advance to provide guidance on how to construct a successful request in accordance with award terms and conditions and sponsor policies.
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