Making Changes to a Sponsored Award

Post-award changes that will change or significantly affect the scope of work will require approval from the sponsor. OSPA, as the authorized institutional official will usually need to formally submit to the sponsor a request for such changes. Requests for OSPA action are initiated in the Research Portal using the appropriate submission form. Even if certain changes can be made without prior approval of the sponsoring agency (under expanded authority), typically these changes will require institutional prior approval.

Some of the most common changes include:

  • Re-budgeting funds within the awarded budget
  • Change in scope of work or specific aims – requires sponsoring agency approval
  • Change in PI – requires sponsoring agency and OSP approval
  • Change in other key personnel – seek clarification from agency
  • Reduction of effort of key personnel (by 25% or more)
  • Absence of key personnel for more than three months (including sabbatical, sick leave, and other types of leave of absence)
Generally, the university is granted broad re-budgeting authority, for which prior approval from the sponsor is not needed. Most federal awards will allow re-budgeting within budget categories of up to 25% of the total budget period award. It is important to read the award terms to determine if a different standard is used or if any budget lines are excepted from the standard.

The budget lines established in Spectrum reflect the sponsor’s terms and/or what is needed to ensure that appropriate spending can occur during the project (i.e.: opening appropriate salary and subcontract lines.) Spending on each line will only be controlled if the sponsor has not granted the university re-budgeting authority. Where prior approval for re-budgeting is not required, these lines may spend into deficit but the budget total will be controlled. OSPA will not re-budget individual lines to eliminate line deficits where the sponsor does not require such rigid controls.

A no-cost extension allows funds to be expended past the original project end date and extends the date that final programmatic and financial reports are due (typically for up to one year). All requests for no-costs extensions must be approved prior to the expiration of the grant.

All no-cost extension requests require a justification for the extension that relates to the completion of the objectives of the award. Requests for no-cost extensions should NOT be made just because funds are remaining.

Under the terms and conditions of many federal awards, the university has the option of extending the project for a period of up to 12 months without having to contact the sponsor for permission if the award is under expanded authorities.

For those grants that require agency approval for a no-cost extension, usually OSPA will contact the sponsor, although it is understood that in some circumstances the request will come directly from the PI due to a personal relationship with the sponsor. In these cases, any notice received from the sponsor should be uploaded into the Portal as part of an NCE request.

Please note that requests to agencies generally take one to two months to process and approve. Therefore, we suggest such requests be submitted 90 days before the expiration of the grant in order to have the approved extension prior to the original expiration date.

PIs should consult with OSPA early in the last year of funding to determine if their award is eligible for a no-cost extension and, if so, if agency approval is required. Also, PIs should be aware of any additional required reporting to the sponsor that may accompany a no-cost extension for a particular award.

Circumstances may on occasion warrant the designation of a new PI/PD. A sponsor must be advised, and permission obtained, before a new PI/PD may be designated. If the PI/PD finds it necessary to nominate someone, such requests must bear the signed endorsement of the department chair and the dean. If the request is made by the department chair, it must be endorsed by the dean. If the PI/PD is the dean, the request should bear the endorsement of the next higher authority. A request to a sponsoring agency for designation of a new PI/PD will normally state the reasons for such change and will include the curriculum vita of the PI/PD-designate. Such requests must be submitted to OSPA for institutional endorsement, before forwarding to the sponsor.
A Principal Investigator who leaves one university or non-profit institution to accept a position at another is generally is allowed to take any active grant and/or pending proposal to the new institution. Since awards are made to the institution and not directly to the PIs, the transferring PI needs to review the award terms and conditions and sponsor policies concerning change of grantee and relocation of PI and then work with a grants administrator at the relinquishing institution to prepare the necessary paperwork and to obtain institutional approval to relinquish the award to the new institution.

Most institutions should have in place a procedure for grant transfers. The sponsor and the relinquishing institution should agree to any transfers and the new institution should give written notice to the relinquishing institution that it will accept the transfer, usually with no changes to the scope of work or the budget, before the transfer paperwork is submitted. Also, it is important to note that the start date of the PI at the new institution does not necessarily coincide with the transfer date of their grants. There are often delays in transferring grants that will result in grant start dates later than the start date of the PI at the new institution. More details can be found in Georgia State's Grant Transfer Procedures.

In most awards, only those key personnel who are named on the award document require sponsor approval prior to the reduction of their effort by 25% or more.  Unless, the award document or sponsor terms state otherwise, all other key personnel effort may be reduced without limitation or sponsor approval.

Absence of award-named key personnel for more than three months including sabbatical, sick leave, and other types of leave of absence requires notification to the sponsoring agency. It is important to contact OSPA and the sponsor to clarify what needs to occur. During any absence of the PI, a temporary PI must be appointed.