Announcement: On December 26, 2013, the Office of Management and Budget (OMB) issued Uniform Guidance that will replace the administrative, accounting, audit rules and principles currently promulgated in OMB Circulars A-21, A-110, and A-133. The Uniform Administrative Requirements, and Cost Principles found at www.ecfr.gov will apply to new and incremental funding awarded on or after December 26, 2014. Existing Federal awards will continue to be governed by the terms and conditions under which they were awarded.
In general, approval of a budget by a sponsoring agency constitutes prior approval for the performance of activities and the expenditure of funds as detailed in the budget. Most agencies will allow the grantee to depart from the original budget provided that:
Note that prior approval is a sponsor function, but NSF, USDA, NASA, NIH and ADAMHA and others have delegated most prior approvals to the University.
In addition, agency approval may also be necessary for changes including, but not limited to, the following:
Budget reallocation (re-budgeting) within a sponsored program, after it is awarded, is allowed if there is a legitimate need to change budgeted costs, provided the reallocation conforms to the sponsoring agency’s guidelines and is consistent with the University’s policies and procedures. Budget reallocation is not allowed for the purpose of relieving financial pressure on a department’s unrestricted budget, or on other sponsored projects to assign costs that could not otherwise be assigned.
The principal investigator may complete the Budget Reallocation Request Sponsored Programs Form addressing the following points:
BUDGET reallocations are allowed for sponsored programs. Budget reallocation entries must be completed through budget request. User must ensure that Facilities and Administrative costs (F&A or indirect costs) are appropriately calculated for each adjustment if required. Entries without proper F&A costs will be reversed and must be resubmitted.
The following are guidelines for calculating F&A costs:
In the event the index has a deficit balance at index closeout, whether resulting from the budget reallocation, an indirect cost adjustment or other transactions, the department overhead index will be charged for the deficit unless the department promptly identifies a funding source for the deficit.
If it is necessary to re-budget for administrative and clerical costs after receiving the sponsored programs award, the following conditions should be met:
The principal investigator should prepare a letter to the sponsoring agency including the following information:
The principal investigator should obtain the countersignature from Sponsored Programs Administration.
Prior approval requirements for the various sponsoring agencies are subject to change; the Office of Sponsored Programs Administration should be contacted for current information.
Failure to obtain prior approval for all actions requiring such approval may result in the disallowance of costs. Retroactive approval is allowed in highly unusual or exceptional circumstances, and when denying such approval would affect in a material manner the successful performance of the project objective. Authorized officials granting retroactive approval shall be held responsible for providing documentation for the grant file regarding the reasons why prior approval was not obtained in a timely manner, the manner in which the project objectives would be adversely affected if approval was withheld, and a certification that approval would have been given had the request been submitted on time.