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Administrative Changes


Scope of work changes

  • Explain and justify the proposed changes.
  • Indicate any changes in funding and/or categorical reallocations.

Change in PI effort

  • Decrease of effort (from percent to percent). For many federal sponsors, this decrease must be more than 25 percent of proposed effort.
  • What rebudgeting might occur and its impact on the project.
  • Duration of change.
  • Justification of need for change and its overall impact on the project.

Change in PI/key personnel

  • CV for proposed PI/key personnel.
  • Other support information.
  • Justification of need for change and its overall impact on the project.

Use of program income

Federal sponsors address program income via OMB Circular A-110 and the applicable Code of Federal Regulations. Additionally, federal sponsors may also provide guidance in their specific policy guidelines which does not necessitate prior approval request unless the alternative provided is not the desired method for handling program income. In the case of non-federal sponsors, if the sponsor proposal guidelines, award terms, and/or policy guidelines remain silent in program income, any income generated under awarded projects will be treated as non-reportable.

Other specific terms and conditions

Many sponsored project agreements require PIs to obtain the sponsor's written approval before specific changes may be made in the project. Approval requirements customarily noted in the Notice of Grant/Contract Award include:

  • unanticipated subcontracts,
  • substantial budgetary changes,
  • building alterations or renovations, and
  • patient care costs.

Rebudgeting

Rebudgeting is the shifting or rebudgeting among budget lines. Sponsors may have limits for how much funds can be shifted or rebudgeted among budget lines, which budget categories can be rebudgeted, or not allow rebudgeting.

Before moving funds from one budget line to another, check the sponsor's policy to determine any established limits or restrictions. For some sponsors, ORSP may have the authority to approve certain rebudgeting requests. In general:

Approval from the sponsor is not required:
For rebudgeting in unrestricted categories.
 
Approval from the sponsor is required:
The sponsor's approval is required if:

  • the rebudgeting indicates a change in the scope of the project,
  • the rebudgeting takes place between restricted categories,

 For information on the sponsor's limitations and requirements, consult the sponsor's policy guide. For federal sponsors, also consult Circulars OMB A-21 and A-110.

Rebudgeting approval process:

  • The PI must write a letter addressed to the sponsor. This letter must identify the reallocations and justify the proposed changes.
  • The letter must be signed be the PI.
  • The letter must be forwarded to the appropriate ORSP project administrator for review and institutional endorsement.
  • ORSP will forward the letter to the sponsor.
  • When written approval is sent by the sponsor, ORSP will complete the necessary rebudgeting on the Banner system.

No-cost extensions

If the project can not be completed by the end date, the PI can continue the work by requesting an extension.
 
A request for a second no-cost extension will be considered by some sponsors, but it must also be properly signed and submitted through ORSP. ORSP must certify that the PI's original institutional extension was properly requested and completed. Most sponsors will not consider any no-cost extension unless it has been signed and submitted through ORSP.

Federal

A no-cost extension means that a sponsor will allow the PI an additional period of time, usually no more than one year, to complete the project and file reports, but will not provide additional funding. Requests for extensions must be submitted far enough in advance to allow proper processing prior to the original end date; generally 60 to 90 days.

Most federal sponsors allow institutions to grant no-cost extensions if a letter of request and explanation is submitted to the institution by the PI. The explanation should:

  • describe why the project could not be finished in the planned amount of time,
  • indicate anticipated balances, both direct and F&A (indirect), and
  • explain how the remaining funds will be used (budget).

The letter should be forwarded to the appropriate ORSP project administrator. Since not all federal sponsors have delegated authority to institutions to grant no-cost extensions, PIs should contact the appropriate ORSP project administrator for information about their particular funding agency.

Note: Not having spent all the allotted funds is not an acceptable reason for requesting a no-cost extension.

Nonfederal

For sponsors other than federal agencies, contact ORSP to determine if extensions are allowed.

Fixed-fee and fixed price contracts must be extended if the project will not be completed by the date on the agreement.

The award agreement with the sponsor establishes a project timeline and creates a schedule for the submission of reports and other deliverables. If a project will not be completed by the end-date on the agreement, then the schedule for deliverables will need to be revised. Because this type of change to the agreement requires mutual written consent by both the University and the sponsor, an extension request is required by the principal investigator. If an extension is not requested, the University could be in breach of the agreement, which increases the risk of nonpayment or the potential for a lawsuit.

A few award agreements are fairly informal and may not reflect project dates. However, because the award was made after some sort of proposal, there is an expectation by the sponsor that the project will be finished by the proposed end date.

To demonstrate good stewardship on the part of the University, we must at least notify the sponsor of the extension.

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