Title
Office of Sponsored Programs - 500.03 - Prior Approval Requests
Purpose
This operating standard is established to adhere to the University’s obligations as a recipient of sponsored projects specifically under 2 CFR §200.308 and the Federal Research Terms and Conditions.
Policy Statement
Unanticipated changes to a sponsored project are sometimes needed after it has been proposed and awarded. Sponsors may require different methods of requesting approval to make such changes. These Prior Approval Requests (PAR) may be able to be approved internally by the Office of Sponsored Programs (OSP) through expanded authorities. Other types of changes require formal authorization from the sponsor.
I. Identifying Changes for Prior Approval
Prior Approval requirements depend on the sponsor and the individual project’s terms and conditions. It is important to identify the guidelines for each project before requesting approval. Standard types of project changes include the following:
- Additional Funding Requests
- Alteration and Renovation Costs
- Budget Revisions that need Sponsor Approval
- Change to the Project’s Scope
- Changing the administrative institution of a project
- Equipment purchases not proposed or at the end of the project
- Foreign Travel
- Changes to Key Personnel and their effort
- Establishing a new foreign component or foreign subrecipient
- Establishing a new subrecipient collaborator
- Requests for No Cost Extensions
- Changes to Patient Care Costs or Participant Costs
- Principal Investigator changes or disengagement
- Pre-Award Spending
- Requesting carryover of unobligated funds from a previous budget period
II. Approval Methods
PARs have two approval methods. The request can be internally approved by OSP or it must be externally approved by the sponsor. Both types of requests must be submitted through OSP. Principal Investigators (PIs) and Departmental Administrators (DAs) are not authorized to communicate PARs directly to the sponsor.
Many Federal sponsors allow the University to approve select types of unanticipated changes for grants and cooperative agreements. This is commonly known as expanded authority, issued through 2 CFR §200.308 and the Federal Research Terms and Conditions. OSP is the designated unit that reviews, approves, and documents such types of prior approvals.
Changes that require external approval require a formal request submitted to the sponsor. This should detail what the change is, how this impacts the project programmatically and financially, and why it is necessary to the project.
OSP is able to provide guidance on the appropriate method of approval and are also authorized to make the final determination on which method is required.
III. Submitting a Prior Approval Request
PARs are created by submitting a Prior Approval Request Form and any additional documentation to OSP (SponsoredPrograms@unc.edu). The form allows the user to select the needed project change and gives instructions on what documentation is needed. OSP will return any requests that are not complete or do not include the required documentation.
Complete requests will then be directed to the appropriate OSP Sponsored Projects Specialist (SPS). The SPS will review the request and all relevant guidance. Once the review is complete, the SPS will either approve or deny the request. Requests for internal approval will then be documented in RAMSeS. Requests for external approval will then be submitted to the sponsor by the SPS.
External approvals will be monitored by the SPS pending the sponsor’s decision. The final approval or denial from the sponsor will then be communicated to the PI and DA once it is received. This response will be documented in RAMSeS.
Exclusions
Federal agencies may provide additional restrictions on prior approvals included in expanded authorities. Such restrictions will be identified in the award.
Related Requirements
Unit Policies, Standards, & Procedures
Contact Information
For questions regarding this operating standard and its related procedure, please contact SponsoredPrograms@unc.edu.
For questions regarding Pre-Award management or Post-Award administration, please contact the assigned Sponsored Programs Specialist.
For invoicing, reporting and other financial matters, please contact the assigned Sponsored Projects Accountant. OSP Staff assignments are found in RAMSeS or on the OSP website.
History
History Table
| Date |
Description |
| 07/01/2022 |
Revised to reflect new office name. |
| 07/15/2018 |
Revised to reference revised PAR form. |
| 05/15/2018 |
Revised to coincide with the release of the new OSP Website. |
The operating standards in the Office of Sponsored Programs Operating Standards & Procedures Manual supersede any OSP operating standards, procedures and appendices previously included in the University Business Manual, a publication of UNC-Chapel Hill’s Division of Finance.