Changes to an Award
Changes made to an original award can take many forms and may require various levels of approval. Regardless of the nature of the changes made, if they are substantial to the project, some approval is required. 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. Approval for changes to an award can be obtained by completing a Institutional Prior Approval (IPAS) Form. This form must be signed by the PI, the department chair and the dean before submitting to OSP. Some of the most common changes include:
- 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)
Re-budgeting within awarded budget line items is usually possible, however, the sponsoring agencies have different restrictions on deviations from the approved budget. It is important to know the terms and conditions of your award. For some, you need sponsor approval only when you rebudget more than 25% of the total project budget; for others you need approval when you rebudget 10% of a budget category. You can consult your OSP officer if you do not know the conditions of your award. When re-budgeting requires approval by the sponsoring agencies, a formal written request with accompanying justification and a completed IPAS Form must be made and processed through OSP. Many awards allow some changes to occur at the discretion of the PI (under expanded authorities). In these cases, the re-budgeting section of the IPAS Form must be completed and sent to the assigned RFS staff if rebudgeting more than 25% of a budget category. (IPAS Form is not required if re-budgeting less than 25% of a single budget category). Also, it is important to remember that when re-budgeting you should not transfer budget from non-Indirect cost-bearing to Indirect cost bearing budget categories. Doing so results in added IDC that the sponsoring agency typically will not cover leaving the university or department responsible for these additional costs. Also, if you transfer budget from IDC-bearing to non-IDC bearing budget categories, you will lose the extra IDC (you cannot use it somewhere else in your budget).
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. 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 these grants, PIs should complete the appropriate sections of the IPAS Form, obtain the appropriate signatures, and submit the request to their OSP officer.
For those grants that require agency approval for a no-cost extension, a PI should prepare a separate written request including 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. These requests must be routed to OSP using the IPAS Form. 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 OSP 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.
Change of PI/PD
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 OSP for institutional endorsement, before forwarding to the sponsor.
Transfer of grant/contract to or from Georgia State
When a Principal Investigator (PI) leaves one university or non-profit institution to accept a position at another, he/she 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 his/her grants administrator at the relinquishing institution to prepare the necessary paperwork and to obtain 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. Georgia State’s Grant Transfer Procedures and related documents can be found with the file finder.
Reduction of effort of key personnel
Prior approval must be obtained from the sponsoring agency anytime there is a decrease in effort of more than 25% of any key personnel listed on a sponsored project. See Personnel Effort Reporting Policy, section on Effort Commitment for policy statement about this. PIs should contact RFS for assistance.
Sabbatical, sick leave or leave of absence
Absence of 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 OSP and the sponsor to clarify what needs to occur. During any absence of the PI, a temporary PI must be appointed.