Written by Allison Nelson, Associate Director, Contracts and Grants.
What is prior approval, and why do I need it?
Prior approval is advanced written approval by a sponsor agency’s authorized official. The authorized official approves specific activities before they occur. An authorized official, for example, is a grants management official, grants management specialist or authorized official. The authorizing official is not the program officer. The program officer may be consulted in the review of the request, but they don’t have the authority to grant approval.
Engaging in activities that require prior approval without obtaining prior approval may result in unallowable expenditures. Unallowable expenses are covered by the college, department or the principal investigator (PI).
Which transactions require prior approval?
Different agencies have different requirements for activities requiring prior approval. You must read your award document in conjunction with the request for proposal (RFP) and any amendments to determine the prior approval requirements for a particular award. The NIH Grants Policy statement provides guidance in 8.1.2 Prior Approval Requirements for federal awards.
Prior approval may be required in the following cases (this list is not exhaustive):
- Change in the scope of work
- Change in PI
- Reducing effort by more than 25%
- Carryover in certain instances
- Certain subawards
- Certain budget revisions
- Foreign subawards
- Certain equipment purchases
When should I submit a prior approval request?
Prior approval requests should be submitted to the authorizing official no less than 30 days before the expected date of the expenditure. Prior approval requests should not be submitted unless required by the agency.