Expanded Authority and Prior Approval

Expanded Authority

During the life of a federally funded grant award, it may become necessary to modify certain aspects of the original award.  For example, these changes could involve re-budgeting of funds among budget categories or extending the length of a project period.  Particular federal agencies have granted institutions with the authority to approve these changes under a mechanism known as Expanded Authority. This expanded authority, which was implemented by the NIH in October of 1988 became standard terms and conditions for all NIH grant awards in October 2001.  Unless specifically excluded in a Notice of Award (NOA), the NIH incorporates expanded authority to grant awardees as described in the NIH Grants Policy Statement.

Examples of expanded authorities include:

  • Carryover of unobligated balances to subsequent funding periods
  • Initiating a one-time no cost extension up to 12 months
  • Entering into a domestic consortium agreement without changing the prime grant awardee's scope
  • Charging salaries of administrative and clerical staff

Sponsor Required Approvals

Principal Investigators of federally sponsored projects are required to report departures from budget and program plans and request formal approval directly from the federal awarding agency. Examples of circumstances requiring prior approval from a sponsor include, but are not limited to:

  • Changes in the scope or the objective of the project
  • Changes in the Principal Investigator or Key Personnel
  • Absence for more than three (3) months, or a 25% reduction in the time devoted to the project by the Principal Investigator or Key Personnel
  • Transfers of funds allocated for training expenses (direct trainee payments, stipends, tuition, fees) to other budget categories
  • Subcontracting a substantive programmatic portion of the work, which results in a change in scope, unless described in the application and funded in the approved award
  • Subcontracting with a foreign entity
  • Equipment not approved in the original award with a cost above $25,000 constitutes a change in the scope of work, mandating approval

Through the eRA Commons Prior Approval module, the NIH allows certain prior approval requests to be made electronically.  This table provides more information on the types of requests that can now be submitted through eRA Commons.

Refer to the Prior Approval Matrix for a more comprehensive list of prior approval requirements for select federal agencies, including NIH, NSF, DOE, USDA/NIFA, NASA, and DOC.