Office of Sponsored Research - 500.03 - Prior Approval Requests

Title

Office of Sponsored Research - 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 Research (OSR) 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 OSR or it must be externally approved by the sponsor. Both types of requests must be submitted through OSR. 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. OSR 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.

OSR 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 OSR (ResAdminOSR@unc.edu). The form allows the user to select the needed project change and gives instructions on what documentation is needed. OSR will return any requests that are not complete or do not include the required documentation.

Complete requests will then be directed to the appropriate OSR 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 ResAdminOSR@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. OSR Staff assignments are found in RAMSeS or on the OSR website.

History

History Table
Date Description
07/15/2018 Revised to reference revised PAR form.
05/15/2018 Revised to coincide with the release of the new OSR Website.

The operating standards in the Office of Sponsored Research Operating Standards & Procedures Manual supersede any OSR operating standards, procedures and appendices previously included in the University Business Manual, a publication of UNC-Chapel Hill’s Division of Finance.

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Details

Article ID: 132307
Created
Thu 4/8/21 9:28 PM
Modified
Thu 7/22/21 11:00 PM
Effective Date
If the date on which this document became/becomes enforceable differs from the Origination or Last Revision, this attribute reflects the date on which it is/was enforcable.
02/19/2021 9:18 AM
Issuing Officer
Name of the document Issuing Officer. This is the individual whose organizational authority covers the policy scope and who is primarily responsible for the policy.
Issuing Officer Title
Title of the person who is primarily responsible for issuing this policy.
Distinguished Professor
Last Review
Date on which the most recent document review was completed.
02/19/2021 9:18 AM
Last Revised
Date on which the most recent changes to this document were approved.
05/09/2019 12:00 AM
Origination
Date on which the original version of this document was first made official.
07/01/2008 12:00 AM
Responsible Unit
School, Department, or other organizational unit issuing this document.
Research