This policy addresses budgetary and other post award changes to sponsored programs. Applicable university and sponsor guidelines, policies, procedures, and regulations govern the course of action required to affect post award changes.
Sponsor rebudgeting and prior approvals policies vary, and it is the principal investigator’s (PI) responsibility to review and take appropriate actions to comply with the terms and conditions of their sponsored award.
Most sponsors require sponsor written approval prior to certain post award changes. In these cases, the university requires approval from the Office of Sponsored Programs prior to submission of the request to the sponsor. Post award changes that often require sponsor prior approval include, but are not limited to, the following:
In addition to the changes listed above, the university requires internal approval from the Office of Sponsored Programs on all other changes, including those listed below:
The above constitutes general rules. The Research Terms and Conditions, Appendix A (Prior Approval Matrix) <https://www.nsf.gov/bfa/dias/policy/fedrtc/appendix_a.pdf> also provides direction regarding prior approval and rebudgeting conditions. PIs are ultimately responsible for being familiar with, and adhering to, the sponsor’s requirements of the award.
Noncompliance with this policy may result in disciplinary action up to and including termination. VCU supports an environment free from retaliation. Retaliation against any employee who brings forth a good faith concern, asks a clarifying question, or participates in an investigation is prohibited.
All individuals involved in sponsored programs are responsible for knowing this policy and familiarizing themselves with its contents and provisions.
The individual(s) formally authorized to bind the institution to grants, contracts and other agreements; the official "signer" for the institution.
Funds that have been obligated by a funding agency for a particular project, or the document memorializing this transaction.
Individuals performing teaching, research, and service duties in support of the university’s mission. These faculty members may hold tenure, serve in tenure-track positions that are eligible to receive tenure or occupy collateral positions that are not tenure-eligible. These positions include academic titles such as professor, associate professor, assistant professor, instructor or lecturer.
Individuals who provide critical leadership positions within the proposal (and consequently their intellectual guidance) or because of the uniqueness of the expertise they are contributing relative to the proposed scope of activity. Key Personnel typically include principal investigators, research scientists, principal scientists and senior scientists, depending on their intellectual contribution to the proposed scope of activity. Typically, replacement of any of these individuals requires approval from the sponsor. Importantly, the status of key personnel does not necessarily imply salary support from the sponsor.
Written documentation from the sponsor memorializing permission for VCU to use project funds for purposes not in the approved budget or to change aspects of the program from those originally planned and approved.
Many federal agencies have delegated to the institution the authority to exercise certain prior approvals required for federal research grants through the expanded authorities designation. These include, but are not limited to, carryover of unobligated balances and up-to-12-month no-cost extension to the final budget period.
The Office of Sponsored Programs officially interprets this policy. This office is responsible for obtaining approval for any revisions as required by the policy Creating and Maintaining Policies and Procedures through the appropriate governance structures. Please direct policy questions to the associate vice president for sponsored programs.
PIs are responsible for initiating prior approval requests and receiving sponsor approval prior to implementing any change(s) in the project. The PI must prepare a request to the sponsor in the format required by the sponsor requesting the prior approval. Some sponsors require these requests to be submitted via their electronic systems. Requests must specifically identify the sponsor’s award number and title. Complete justification of the request (including a revised budget, if applicable) must be included. Requests must be submitted to Office of Sponsored Programs (OSP) (prior to submission to the sponsor) as an Administrative Action through the Research Administration Management System – Sponsored Programs Online Tracking system (RAMS SPOT) for review, countersignature by VCU’s Authorized Official, and submission to the sponsor for consideration. These requests must be submitted in accordance with the RAMS SPOT Get Started Guide for Administrative Actions. Sponsor approval must be obtained in accordance with the award terms and conditions and oftentimes will be in the form of an amendment or modification to the award. Responses received from the sponsor by the department or PI must be forwarded to OSP for processing. When approved, OSP will process the change in RAMS-SPOT and notify the Grants & Contracts Accounting Office of such changes.
Special Instructions and Notes for No-Cost Extensions: Extensions may be requested for programmatic reasons only as long as funds remain. Some sponsors may request information about the amount of funds remaining in the account and others may request a budget indicating how funds remaining at the end of the original project period will be spent during the extension. When in doubt, consult the original award and/or the OSP.
Timing: To accommodate time limits for sponsors, requests for extensions must be submitted to OSP at least four weeks before the grant period ends. Please refer to the sponsor agreement or guidelines if there are any questions regarding timing.
Change of Effort on Sponsored Award– Requests must be submitted to OSP as an Administrative Action through RAMS SPOT for review and approval. OSP maintains “committed effort” records for all key personnel. These data are used by the eCRT program for effort certification
One-time 12-month no-cost time extension:
Federal Awards– Many (but not all) federal agencies have delegated the responsibility for approving initial 12-month no-cost extensions to the university’s Authorized Official for grants to the institution. This delegation allows OSP to internally approve a one-time request to extend the end date of the project period up to an additional 12 months. Please review the Research Terms and Conditions, Appendix A (Prior Approval Matrix) for information regarding which federal agencies have delegated this responsibility.
Procedure for Internal Approval: Requests must be submitted to OSP as an Administrative Action through RAMS SPOT for review and approval. OSP will then electronically submit the notification to the sponsor.
Upon approval, OSP will process the change in RAMS-SPOT and notify the Grants & Contracts Accounting Office of such changes.
Exception for NSF awards: NSF requires that notification of extensions be submitted through FastLane. The PI or research administrator must initiate the notification procedure through FastLane and also complete and submit an Administrative Action through RAMS-SPOT. OSP will forward the notification to NSF via FastLane.
Timing: The sponsor must be informed about the extension well before the original expiration date. Therefore, requests for extensions must be processed at least four weeks before the grant period ends.
Non-Federal Awards and Federal Awards that have not delegated to University-
When it is necessary to request a no-cost extension from a non-federal sponsor or from a federal agency that requires agency approval for extensions, the PI must write a letter to the appropriate official as identified in the award document (usually Program Officer or Grants Management Officer) or complete the appropriate form in the sponsor’s electronic system. The letter must include: 1) justification for the no-cost extension; 2) the sponsor’s award number; 3) the new requested expiration date; 4) PI signature; and 5) OSP countersignature. Submit the request to OSP (prior to submission to the sponsor) as an Administrative Action through RAMS-SPOT for review, countersignature by VCU’s Authorized Official, and submission to the sponsor for consideration.
When approved, OSP will process the change in RAMS-SPOT and notify the Grants & Contracts Accounting Office of such changes.
Non-federal contracts such as pharmaceutical company clinical trials often do not specify an end date in the contract but the university requires an end date be associated with the account. Requests must be submitted by the PI or department to OSP as an Administrative Action through RAMS SPOT for review and approval.
** Reminder: All terms and conditions of the award remain in effect during the period of a no-cost extension, including effort commitment of the key personnel named in the notice of award.**
There are no forms associated with this policy and procedures.
This policy supersedes the following archived policies:
|01/07/2013||Post Award Changes - Rebudgeting, Prior Approvals and University Expanded Authority Approval|