Sponsor Prior Approval Requests

A change in the research scope from what was originally proposed and approved requires sponsor approval. 

Changes in research scope may include:

• changes in objectives or specific aims
• changes in strategy and methodology
• significant changes, delays, or events of unusual interest
• changes from approved human and/or vertebrate animals research
• shift in research emphasis

PIs are encouraged to consult with the Sponsor/Program Officer (PO), RST, and OSP before submitting a formal request. 

A no-cost extension (NCE) grants the PI added time to complete the project’s scope of work without additional funding. 

Sponsor approval is necessary to extend projects: 

• without expanded authority
• requiring an extension beyond the Grantee Approved No Cost Extension (GANCE)

At minimum, requests for extension must provide the period of extension and programmatic justification. Other details, including plans for use of unobligated balances during the requested period may be needed based on sponsor requirements. 
 

Certain changes in budget plans may require prior approval from the sponsor, even if the revisions do not impact the approved scope of work. Grantees are required to adhere to sponsor guidelines and award restrictions.  

Budget changes that may require sponsor approval include (but are not limited to):

• transfer of funds budgeted for participant support costs
• re-budgeting trainee costs
• purchase of a unit of equipment over 25K not previously requested and approved
• significant changes to the approved budget categories based on sponsor threshold
• changes in the total approved cost share
• budget changes to accommodate subawards not previously requested and approved
• budget changes to incorporate international activities or foreign component 

Subawarding, contracting, or transferring substantive programmatic award research performance often requires sponsor’s approval.  Additional documentation may be needed to request foreign and/or fixed price subawards. 

If approved by the sponsor, GW, as a grantee, is held accountable for subrecipient compliance.  

Procurement transactions for goods and services do not fall under this provision. 

Pre-award costs are defined as allowable costs incurred prior to the effective start date of an award and are necessary for efficient and timely performance of the scope of work. 

Sponsor approval is required:

• if the requested pre-award date incorporates a period over 90 days for an award under expanded authority
• for awards not granted expanded authority

Pre-award costs must be charged to the initial budget period of the award, unless otherwise approved by the sponsor. 

Sponsored projects are awarded to GW and executed through legal agreements. 

PIs who terminate their employment with GW and wish to transfer corresponding research to a new institution should initiate a request for award relinquishment through their RST at the earliest opportunity. The request to transfer an award must be approved at GW before it can be submitted to the sponsor by OSP. 

The Uniform Guidance provides detailed definitions related to foreign organizations and foreign public entities (200.1)

The NIH Grants Policy Statement defines a foreign component as the performance of any significant element or segment of the project outside the United States either by the grantee or by a researcher employed by a foreign institution, whether or not grant funds are expended. 

Most sponsors require grantees to request prior approval to add a foreign component to a grant. Furthermore, the increasing need for transparency and security demands a thorough review and compliance with sponsor restrictions.