OSP Monthly: Did you know?

Once a sponsor has issued an award notice, a Principal Investigator has wide leeway to make the decisions that make their projects run—after all, the sponsor has thoroughly reviewed their intended strategies and methods  and approved them, based on the project team’s qualifications and credentials. But what happens if something emerges that causes the program to want to veer off that sponsor-approved track? If a PI wants to make significant changes to the scope of work, key personnel effort, or the project budget, the sponsor’s prior approval may be required.

Prior Approval is a sponsor’s express, written consent to a change in the approved project that must be obtained before that change is enacted. While a PI is encouraged to have discussions about such changes with the sponsor’s technical point of contact in advance of making a Prior Approval Request, official requests must be made by a UMBC Authorized Organizational Representative (that is, your Grants and Contracts Manager) to the sponsor’s administrative contact.

Take a look at a few common reasons you might need to consider a Prior Approval Request. You can find a comprehensive list of Prior Approval requirements by using a sponsor’s Prior Approval Matrix – here are the matrices for the NSF and NIH. For the NASA prior approval matrix, navigate to page 48 of this document. Keep in mind that while the following may apply to grants and cooperative agreements, other award instruments (like contracts, other transaction authorities, etc) may not.

If ever these situations arise in one of your projects, contact your Grants and Contracts Manager as far in advance as you can with the requested change, a strong justification for the change, and any relevant revised documents, like a budget and scope of work. Please remember that prior approval requests take time—a departmental administrator needs time to collect justifications and revise budgets; your OSP Manager needs time to evaluate the request and ask for revisions; and ultimately, the sponsor may take up to several weeks to consider and evaluate your request--for example, NASA requires that requests for second NCEs be submitted no later than 45 days in advance!