Prior approval requests are submitted during the current period at the time of change and before the RPPR is submitted. It is the responsibility of the Principal Investigator (PI) to adhere to the conditions of the sponsored award. As such, the PI occasionally identifies a need to change or deviate from the sponsor-approved proposal. In some instances, these changes require prior approval from an authorized official of the sponsor. In other cases, prior approval from VUMC's Office of Sponsored Programs is sufficient. The level at which approval may be granted depends upon the type of grant and the sponsor's grant-type-specific policies.
When the sponsor requires prior approval, such requests are to be put in writing and submitted to OSP in advance of the change in order to allow OSP to submit to the sponsor's authorized official for a decision. Requests for retroactive approval are to be avoided.
An authorized official from the Office of Sponsored Programs must sign all prior approval requests being submitted to sponsors. If "internal" approval is sufficient, a brief memo requesting approval of the change should be signed by only the PI and sent to OSP. After a decision is made by OSP concerning the request, the original will be returned to the department administrator and a copy kept in Coeus as internal documentation.
Instructions regarding how to process a prior approval request (internal and external) depend on the action to be taken.
For changes that may affect the technical or scientific work of the project, the PI should have preliminary discussions with his/her technical counterpart at the sponsor (i.e. the Project Officer or other similar individual). This technical counterpart is rarely the individual who can make an official decision on behalf of the sponsor, but the person's recommendation often is given significant weight by the official decisionmaker.
Internal/Expanded Authority
When the sponsor has given the Medical Center expanded authority, the PI is responsible for preparing and submitting all requests to OSP for a decision. Once approval has been granted, OSP maintains a copy of the written approval and processes the approved documents.
External Approval Required
The department administrator, in collaboration with the PI, is responsible for preparing and submitting all requests in writing to OSP in compliance with the instructions for approval before they are submitted by OSP to the authorized official at the sponsor.
Prior Approval is Required When:
Re-budgeting
Re-budgeting is the process by which the PI produces a revised plan for spending awarded funds. It may be necessary to produce a new budget if there is a change in project scope, a need for supplemental funding, or the generation of unexpected program income. Most sponsors place restrictions on budget revisions, including limits on moving funds from one category to another. Significant changes to the budget almost always require prior approval by the authorized official of the sponsor.
Change in Scope
In general most sponsors require grantees to inform them of any changes that may affect the scope of the actual research being performed. These often involve a change in the objective of the study but may also involve the absence/removal/change of a PI (see below), a change of grantee institution, a change in the approved use of animals or human subjects, or other factors.
Effort Changes
Significant decreases in effort (> or = to 25%) for individuals named in the award are deemed a prior approval requirement for most sponsors (please review award terms and conditions). Oversight and engagement is required to ensure proper reviews, approvals, and certifications are processed and follow VUMC's effort certification and direct charge policy for all effort changes. Any effort changes requiring agency prior approval must be reported in a timely manner to sponsors.
While prior approval is not required, significant increases may occur, and these changes must be clearly monitored following the same VUMC effort and direct charge principles. Significant increases are relative based on the sponsor-approved committed level of effort. While any effort change must be properly allocated and allowable, for consistency in review, a 200% change will be used as the basis for a potential 'significant' increase.
For example, a PI with 5% committed effort changing to 15% (a 200% change) is reasonable given the ebb and flow of programmatic scientific activity, while a PI moving from 25% to 75% (a 200% change), could represent and warrant additional targeted questions by the department administrator during regularly scheduled (a monthly best practice) portfolio review to support this change and during the PCA or PAA process or the quarterly effort certification review.
Absence/Removal/Change of Key Personnel
Prior approval is generally required for any absence of the PI lasting three months or more. In some instances, the change of other key personnel on the project also requires prior approval.
Equipment
Subject to the terms and conditions of the award, the PI may often approve the acquisition of items of equipment not listed in the approved grant budget, provided that the cost of each item is less than the sponsor's threshold for prior approval. Any items costing more than the sponsor's threshold require prior approval. Some sponsors prohibit the purchase of equipment within six months of the project period end date, so deviations from this restriction also require prior approval.
International Travel
The sponsor's terms and conditions should specify international travel conditions. Requests for international travel should first be submitted with detailed justification to OSP for submission to the authorized official at the sponsor. Requests for international travel should be made at least thirty (30) days in advance of the anticipated travel date.
Use of an Unobligated Balance
Unless otherwise determined by the terms and conditions of the award, the authorized official at the sponsor determines whether or not a balance at the end of one funded project segment can be carried forward to a new budget period. Prior written approval from the authorized official at the sponsor is required in these instances.
Approval of a Subcontract and Sub-Agreements Not Included in the Proposal
Subcontracts and sub-agreements that were not included in the proposal may require prior approval before the execution of a formal agreement or the commencement of work. Documentation of a subcontractor's qualifications must be provided to secure approval to perform the work and the project's need for such services.