Prior Approvals for Post Award Grant Actions SOP

This standard operating procedure (SOP) includes the following sections: Purpose, Procedure, Contacts, and Links.

Purpose

To change a funded project in a way that requires prior approval from NIAID.

Procedure

While principal investigators (PIs) can perform a range of grant actions under the NIH standard terms of award, they must get prior approval from NIAID for the following things:

  • Change in scope. Get details at Changes to Project or Budget.
  • Transfer of a grant from one institution to another.
  • Change of recipient organizational status, for example
    • Change in institution name
    • Merger
  • Change in key personnel listed on the Notice of Award (NoA).
    • Change of PI, change from a single PI to a multiple PI award, or removal of PIs from a multiple PI award. See the Change of Principal Investigator SOP.
    • Change in PI status, e.g., restrictions on access to institution’s resources.
  • Reduction of PI effort by 25 percent or more.
  • Addition of a new foreign site, foreign subaward, or foreign collaboration.
  • For small business innovation research or small business technology transfer recipients only, addition of a new domestic subaward.
  • Revisions to an approved Data Management and Sharing (DMS) Plan.
  • Deviation from terms of award or restrictions reflected on the NoA.
  • Carryover of unobligated balances if not authorized on the NoA.
  • Late no-cost extension requests or requests beyond 12 months after the end of the grant period. For more information, read the No-Cost Extension SOP.
  • Alterations and renovations:
    • Rebudgeting more than 25 percent of a budget period's total approved budget into alterations and renovations costs.
    • Any alterations and renovations project exceeding $500,000.
    • Major alterations and renovations costs for any foreign grant.
  • Rebudgeting of funds from trainee costs to other budget categories.
  • Rebudgeting of salary and fringe benefits for investigators who receive career development awards.
  • Capital expenditures (construction or acquisition of land or building).
  • Transfer of funds between construction and non-construction work.
  • Prior approval is required for subawards based on fixed amounts when:
    • New fixed amount subawards are added to grants.
    • Competing applications do not identify plans to issue fixed amount subawards and subsequently request approval.
    • Previously existing fixed amount subawards are substantially modified resulting in a change in scope.

Please note that prior approval is not required for charging preaward costs before the start date of a noncompeting grant (the grant resulting from your progress report). In addition, keep in mind that incurring preaward costs does not obligate NIH to make the award or provide budget increases.

Read more about prior-approval requirements in section 8.1 Changes in Project and Budget in the NIH Grants Policy Statement.

Principal Investigators

  • For all requests, get your institutional business official to send prior approval requests to NIAID within 30 days of the planned use of funds.
    • NIAID highly encourages electronic submissions in the eRA Commons/Prior Approval module for requests for prior approvals. Electronic submissions in eRA helps tracking and ensures these requests are reviewed in a timely manner.
      • Note: Currently, prior approval requests can be accepted through an email to your grants management specialist, with a copy to your program officer.
      • When submitting through eRA, please ensure that you select the applicable prior approval dropdown option for the request (e.g., no cost extension request, change of PD/PI request, carryover request).
        • Do not submit the prior approval action using “other request” when the appropriate option is available. 
        • “Other request” must be used only for prior approval requests for revisions to DMS plans.
    • When submitted via email, make sure the request includes the following information:f
      • Grant number in the subject line.
      • Your name, title, organization, telephone number, and email address.
      • Authorized business official’s name and title, telephone number, and email address.
      • Justification for the proposed change.
    • You don't sign letters, but you must have a signature assurance on file.
    • If you spend grant funds or make any of the changes above without written approval, NIAID may audit your institution, terminate your award, or disallow some costs.
  • For changes in scope, use the NIH Template to document your revised Abstract, Specific Aims, and Public Health Relevance after discussing with your program officer. The completed NIH Template should be included as part of the Change in Scope request.
  • For mergers, acquisitions, and other successor-in-interest actions, have your institution respond to the Successor-in-Interest (Type 6 Parent) announcement.

  • To transfer a grant to another institution*, ensure the following occurs at least 2 months before you move:

    * Keep in mind that NIAID will not consider or approve the transfer of a grant in a no-cost extension, except under an extraordinary circumstance. If you believe you have an extraordinary circumstance NIAID should consider, contact both your assigned grants management specialist and program officer prior to requesting a transfer of a grant in a no-cost extension. NIAID generally does not transfer multiproject grants due to the complexity and potential disruption to synergy amongst the Cores and Projects.

Grants Management Specialists

  • Do the following within 5 to 7 working days of receiving a request:
    • Confirm receipt of the request by sending a Prior Approval Request—Initial Response email to the recipient.
  • You have up to 30 days to review the following:
    • Determine if the proposed change is allowed.
    • Seek guidance from the appropriate division coordinator when required (e.g., if disapproving a request).
    • Receive comments and concurrence from program staff, followed by approval or disapproval from GMP staff.
  • If GMP staff
    • Approves a request, issue a revised NoA approving the request. 
    • Does not approve a request, email the recipient a Disapproval Letter.
  • Upload all correspondence and GMP staff approval and disapproval letter into the official grant file.

Program Officers

  • Provide advice to grants management specialists on prior approval requests.
  • Provide comments and concurrence for the official file.
  • If approval will result in a change in scope ensure the Abstract, Specific Aims, and Public Health Relevance has been updated in RePORTER by contacting the eRA Helpdesk.

Contacts

Recipients with questions should contact the program officer or grants management specialist listed in the eRA Commons. For more information, read Contacting Program Officers and Grants Management Specialists.

If you have a general question or a suggestion to improve this page, email the Office of Knowledge and Educational Resources at deaweb@niaid.nih.gov.

Links

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