PI Handbook - Federal Prior Approval Requirements
PIs must be aware that certain changes to federally funded projects require prior written approval from the awarding agency or pass-through entity. These requirements are outlined in 2 CFR § 200.308 (Revisions to Budget and Program Plans) and 2 CFR § 200.407 (Prior Written Approval).
The following changes must be approved in advance:
- Change in Scope or Objectives
Any significant change in the scope or objectives of the project, even without a budget revision. - Change in Key Personnel
Substitution or disengagement of key personnel identified in the award (e.g., PI or Co-PI), including:- Absence from the project for more than three months.
- Reduction in time devoted to the project by 25% or more.
- Transfer of Award
When a PI is transferring to a new institution, prior approval is required to transfer the award. - Budget Revisions
- Reallocation of funds that affect the scope or objectives.
- The transfer of funds budgeted for participant support costs to other budget categories.
- Inclusion or reallocation of costs that require prior approval under Subpart E (e.g., participant support costs, equipment purchases).
- Subawards or Contracting Out Work
If not described in the original proposal, prior approval is needed to subcontract a portion of the work. - Carryforward of Funds
Some agencies require prior approval to carry forward unobligated balances to a new budget period.
Cost sharing refers to the portion of project costs not paid by federal funds. It may be mandatory (required by the sponsor) or voluntary (offered by the institution). Key points include:
Voluntary Committed Cost Sharing is discouraged and cannot be used as a merit review factor unless explicitly authorized in the funding opportunity.
Allowable Cost Share Contributions must:
- Be verifiablein institutional records.
- Not be used for any other federal award.
- Be necessary and reasonablefor the project.
- Be allowableunder cost principles (Subpart E).
- Not be paid by the federal government under another award (unless authorized).
- Be included in the approved budget, if required.
- Conform to all other applicable federal regulations.
Unrecovered Indirect Costs may be used as cost share with prior approval.
Valuation of In-Kind Contributions (e.g., donated services, property) must follow Subpart E cost principles and be based on fair market value.
Important: Any cost sharing commitment—whether required or voluntary—must be tracked and reported. Failure to meet cost share obligations can result in disallowed costs or audit findings.
Program income is defined as gross income earned by the recipient or subrecipient that is directly generated by a supported activity or earned as a result of the federal award during the period of performance. Examples include:
- Fees for services performed
- Use or rental of real or personal property acquired under the award
- Sale of commodities or items fabricated under the award
- License fees and royalties on patents and copyrights
Key Requirements
- Use of Program Income:Must be used for the original purpose of the federal award and expended before requesting additional federal funds.
- Timing:Income must be earned and used during the period of performance or for allowable closeout costs.
- Disposition Methods:There are three methods for applying program income:
- Deduction– Reduces the total allowable costs of the project.
- Addition– Adds to the total allowable costs, increasing the total project budget.
- Cost Sharing/Matching– Used to meet the non-federal share of the project.
Note: If the federal agency does not specify a method, the deduction method is the default. However, for institutions of higher education and nonprofit research institutions, the addition method is used by default unless otherwise stated.
- Post-Performance Income:There are no federal requirements for income earned after the period of performance unless specified in the award terms.
- Costs of Generating Income:May be deducted from gross income to determine net program income, if authorized and not already charged to the award.
Department of Health and Human Services
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NIH prior approval is required for |
Under the following circumstances |
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Additional no-cost extension, extension greater than 12 months, or late notification of initial no-cost extension (8.1.2.1) |
All instances. Per NOT-OD-25-110: All extension requests currently require prior approval- Automatic grantee approved extensions temporarily disabled |
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Alterations & Renovations (8.1.2.2) |
Rebudgeting into A&R costs that would exceed 25 percent of the total approved budget for a budget period. If rebudgeting would not meet this threshold but would result in a change in scope. Addition of a Major single A&R project. |
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Capital expenditures (construction, land, or building acquisition) (8.1.2.3) |
All instances. Also, any proposals to convey, transfer, assign, mortgage, lease, or in any other manner encumber real property acquired with NIH grant funds. |
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Carryover of unobligated balances (8.1.2.4) |
If the NoA indicates that the recipient does not have the authority to automatically carry over unobligated balances. |
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Change in scope (8.1.2.5) |
All instances. |
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Change in status of the PD/PI or senior/key personnel named in the NoA (8.1.2.6) |
A significant change in the status including but not limited to withdrawal from the project; absence for any continuous period of 3 months or more; reduction of the level of effort devoted to project by 25 percent or more from what was approved in the initial competing year award. |
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Change of recipient organization (8.1.2.7) |
All instances. |
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Change of recipient organization status (8.1.2.8) |
All instances. |
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Deviation from award terms and conditions (8.1.2.9) |
All instances. Includes undertaking any activities disapproved or restricted as a condition of the award. |
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Foreign component added to a grant to a domestic or foreign organization (8.1.2.10) |
All instances. NOT-OD-25-104: Effective May 1, 2025, NIH will no longer issue new, renewal, or continuation awards to domestic or foreign institutions that include a subaward to a foreign entity, and will not accept prior approval requests to add new foreign subawards or components to ongoing projects |
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Make subawards based on fixed amounts (8.1.2.11) |
All instances |
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All instances, including extension of a final budget period of a project period with additional funds. |
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Pre-award costs (8.1.2.14) |
More than 90 days before effective date of the initial budget period of a new or competing continuation award; always at the recipient's own risk. |
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Rebudgeting funds from trainee costs (8.1.2.15) |
All instances. |
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Rebudgeting of funds between construction and non-construction work (8.1.2.16) |
All instances. |
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Retention of research grant funds when CDA awarded (8.1.2.17) |
All instances. |
https://www.nsf.gov/awards/terms-conditions
Prior Approvals
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NSF prior approval is required for: |
Under the following conditions: |
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Change in the scope or the objective of the project or program (PAPPG ChapterVII.B.1.a) |
All instances. |
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Change in Principal Investigator (PI) and any co-PIs identified by name or position on the project (PAPPG Chapter VII.B.2)
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All instances. |
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PI disengagement (PAPPG Chapter VII.B.2.a) |
Disengagement from the project for more than three months, or a 25 percent reduction in time and effort devoted to the project over the course of the period of performance, by the approved PI |
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Transfer of funds budgeted for participant support costs to other budget categories (GC-1 Term and Condition No. 3)
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All instances. |
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Addition of subaward activity (PAPPG Chapter VII.B.4) |
Required for all Subaward activities not included in the proposal and approved in the award; this requirement does not apply to procurement transactions for goods and services. |
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Changes in the total approved cost-sharing amount (PAPPG Chapter VII.C)
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All instances |
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Need arises for additional Federal funds to complete the project (PAPPG Chapter VI.E.5) |
All instances |
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Transferring funds between the construction and non-construction work under a Federal award (GC-1 Term and Condition No. 2) |
All instances |
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No cost extensions (PAPPG ChapterVI.D.3.c) |
A no-cost extension or extension of more than 12 months Notification to NSF via research.gov is still required in order to activate fist grantee approved NCE
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Pre Award costs (PAPPG Chapter X.A.2.b) |
Required in order to incur project costs more than 90 calendar days before the start date of the award |
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Fixed amount subawards (GC-1 Term and Condition No. 2) |
Subawards based on fixed amounts up to $500,000; fixed amount subawards must meet the requirements of 200.201 |
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Compensation (PAPPG Chapter X.B.2) |
Faculty salary in excess of institutional base salary |
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Encumber equipment acquired with Federal funds (PAPPG Chapter IX.E) |
All instances |
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Transfer of title to NSF or to a third party designated/approved by NSF (PAPPG Chapter IX.E) |
All instances |
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Direct charge capital expenditures for buildings and land use (PAPPG Chapter IX.E) |
All instances |
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Capital expenditures for improvements to land, buildings, or equipment that materially increase their value or useful life (PAPPG Chapter IX.E) |
All instances |
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Exchange rate fluctuations that result in the need for additional Federal funding, or a reduction in the scope of the project |
PAPPG Chapters VI.E.5 and VII.B.1.a |
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Costs resulting from recipient or subrecipient violations of, alleged violations of, or failure to comply with, Federal, State, local, Tribal, or foreign laws and regulations |
All instances |
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Fund raising costs for the purposes of meeting the Federal program objectives |
All instances |
Other NSF PI requirements
A one-page Mentoring Plan is required for all graduate students and postdoctoral researchers supported by the project.
PI Responsibilities:
- Include a Mentoring Plan in the proposal. If not included and a graduate student or postdoc is later added, you must author a plan and submit it to PostAward for NSF review.
- Report mentoring activities in annual and final project reports.
- Use a single plan that may differentiate between graduate students and postdocs.
Action Required:
- If a Mentoring Plan was not submitted with the proposal, email a new plan to postaward@uta.edu.
- Refer to NSF guidance: NSF Mentoring Plan Guidance
An IDP must be developed and maintained for each graduate student or postdoc receiving substantial support (at least one month per reporting year).
PI Responsibilities:
- Develop and update IDPs annually.
- Certify in annual and final reports that IDPs are in place.
- Ensure IDPs are available for NSF audits or requests.
Action Required:
- Create and update IDPs annually for each qualifying individual.
- Submit copies to postaward@uta.edufor documentation.
A Plan for Safe and Inclusive Working Environments is required for any off-campus or off-site research.
PI Responsibilities:
- Author and distribute the plan to all participants beforethey leave campus.
- Maintain a separate plan for each off-site location.
- Ensure the plan is retained in institutional records.
Action Required:
- If not submitted with the proposal, develop the plan and distribute it to all off-site participants.
- Submit a copy to postaward@uta.edufor documentation.
As a Principal Investigator (PI) or co-Principal Investigator (co-PI) on an NSF award made on or after May 20, 2024, you are required to complete an annual certification in Research.gov confirming that you are not a party to a Malign Foreign Talent Recruitment Program (MFTRP).
PI/ co PI Responsibilities:
- Complete the MFTRP certification annually in Research.gov if named on an NSF award made on or after May 20, 2024.
- Ensure you are not a party to a MFTRP, as this disqualifies you from serving as senior/key personnel on any NSF proposal or award.
- Maintain awareness that this requirement currently applies only to PIs and co-PIs, but NSF plans to expand it to all senior/key personnel.
- Retain a record of your certification under the Academic/Professional Information section of your Research.gov profile.
Action Required:
- Log in to Research.gov and complete the MFTRP certification when prompted.
- If you have multiple active NSF awards, you only need to certify once per year.
- After completing the certification, email a copy to the PostAward office at postaward@uta.edufor institutional documentation and compliance tracking.
https://www.cprit.texas.gov/media/2756/policy_and_procedure_guide_6212022.pdf
CPRIT Prior Approval Requirements for Common Budget Items
- Equipment
- Definition: Tangible personal property with a useful life of more than one year and a per-unit cost of $5,000 or more.
- Prior Approval Required: Yes.
- Notes: Must be itemized in the approved budget. Any equipment not included in the original budget requires prior written approval from CPRIT.
- Travel
- Domestic Travel: Allowed if directly related to the project and included in the approved budget.
- International Travel: Requires prior written approval, for every individual trip. Request should include locate, trip dates and names of travellers
- Notes: Must follow state travel guidelines and be reasonable and necessary.
- Personnel
- Key Personnel Changes: Any change in PI or other key personnel requires prior approval.
- Effort Changes: A reduction of 25% or more in effort for key personnel also requires prior approval.
- New Positions: Adding new personnel not included in the original budget may require prior approval, especially if it affects the scope or budget significantly. PLOE must be updated as new personnel as added.
- Salary Limits:
- The maximum salary supported by CPRIT grant funds for an individual working at 100% effort is $225,000 per year.
- If a principal investigator is working on multiple CPRIT grants, CPRIT may allow a maximum of $225,000 per grant project.
- CPRIT has sole discretion to approve salary amounts exceeding this limit. Such approval must be documented through a contract amendment.
- Subawards and Consultants
- Subawards: Require prior approval if not included in the original budget.
- Consultants: Must be justified and included in the approved budget. Any new consultant agreements require prior approval.
- Budget Reallocations
- Threshold: Reallocations exceeding 10% of the total approved budget or any change that affects the scope of work require prior approval.
- Notes: Budget changes must be submitted through a formal budget change request. All budget transfers must be submitted via CGMS regardless of 10%
- Program Income
- Use of Program Income: Must be reported and used in accordance with CPRIT guidelines. Prior approval is required for how it will be applied to the project
- Food and Beverage
- Allowability: Generally unallowable.
- Exceptions:
- If food costs are specifically approved as part of the grant award for an educational purpose
- If food and beverage costs are part of a per diem or subsistence allowance provided in conjunction with allowable travel.
- Prior Approval Required: Yes, unless already included in the approved budget under the above exceptions
https://www.onr.navy.mil/work-with-us/manage-your-award/manage-grant-award/grants-terms-conditions
ONR Prior Approval Requirements for Budget and Program Revisions
- Equipment
- Prior Approval Required: Yes, for equipment with a unit cost over $25,000.
- Waiver: Prior approval is waived for equipment costing $25,000 or less.
- Travel
- Prior Approval Required: Only if travel costs fall under categories requiring prior approval per cost principles (see FMS Article III).
- International Travel: May require prior approval depending on the award terms.
- Personnel
- Change in Key Personnel: Requires prior approval.
- PI/PD Disengagement: Prior approval required if the PI or PD is disengaged for more than 3 months or reduces effort by 25% or more.
- Scope of Work
- Change in Scope or Objectives: Requires prior approval, even if no budget changes are involved.
- Subawards
- New Subawards: Require prior approval if not included in the original approved budget.
- Note: Does not apply to procurement of supplies, equipment, or general support services.
- Cost Sharing/Matching
- Changes: Any change in cost sharing or matching contributions requires prior approval.
- Additional Federal Funds
- Requests for Additional Funds: Require prior approval.
Process for Requesting Approval
- Requests must be submitted to postaward@uta.edu
- PostAward will review, obtain all needed information and facilitate submission through appropriate sponsor procedure
- Once approved, PostAward will distribute approval to PI and appropriate individuals. PostAward will also update appropriate systems.
Important Notes
- Some prior approval requirements may be waived for research awards, depending on the agency’s terms and conditions.
- Please contact postaward@uta.edu whenever you anticipate a change so our office can review and evaluate for prior approval requirements.