Vanderbilt University - Office of Sponsored Programs

Prior Approval Guidance

It is the responsibility of the Principal Investigator (PI) to adhere to the conditions of the sponsored award. Occasionally, the PI identifies a need to change or deviate from the sponsor-approved proposal. In some instances, these changes require prior approval of an authorized official at the sponsor. In other cases, prior approval from the Office of Sponsored Programs is sufficient. The level at which approval may be granted depends upon the type of grant and the sponsor’s specific policies for that type of grant.

When the sponsor requires prior approval, such requests are to be put in writing and submitted to OSP in advance of the change for OSP’s submission to the authorized official at the sponsor for a decision. Requests for retroactive approval are to be avoided. An authorized official from the Office of Sponsored Programs must sign all prior approval requests to sponsors. If “internal” approval is sufficient, a brief memo requesting approval of the change and signed by the PI only, should be sent to OSP. After a decision is made by OSP concerning the request, this memo will be returned to the Departmental Administrator and a copy kept with the grant as internal documentation. Instructions regarding how to process a prior approval request (internal and external) depend on the action to be taken. Please visit "Related Information" for detailed instructions specific to various prior approval requests.

For changes that may affect the technical or scientific work of the project, the PI should have preliminary discussions with his/her technical counterpart at the sponsor (i.e., the Project Officer or other similar individual). This technical counterpart is rarely the individual who can make an official decision on behalf of the sponsor, but the person’s recommendation is often given significant weight by the official decision-maker.

When Vanderbilt has Expanded Authority

When the sponsor has given the University expanded authority, the PI is responsible for preparing and submitting all requests to OSP for a decision. Once approval has been granted, OSP maintains a copy of the written approval and processes the approved documents.

When Approval from the Sponsored is Required

The Departmental Administrator in collaboration with the PI is responsible for preparing and submitting all requests in writing to OSP following the instructions for approval before they are submitted by OSP to the authorized official at the sponsor.

Common Reasons in which Prior Approval is Required

Re-budgeting: Re-budgeting is the process by which the PI produces a revised plan for spending the awarded funds. It may be necessary to produce a new budget if there is a change in project scope, a need for supplemental funding, or the generation of unexpected program income. Most sponsors place restrictions on budget revisions, including limits on moving funds from one category to another. Significant changes to the budget almost always require prior approval by the authorized official of the sponsor.

Change in Scope/Effort: In general most sponsors require that they be informed of any changes that may affect the scope of the actual research being performed. These often involve a change in the objective of the study, but may also involve the absence or change of a PI (see below), a change of the grantee institution, a change in the approved use of animals or human subjects, or other factor.

Absence or Change of Key Personnel: The prior approval of the authorized official of the sponsor is generally required for any absence of the PI lasting three months or more. In some instances, change of other key personnel on the project also requires prior approval.

Equipment: Subject to the terms and conditions of the award, the PI may often approve the acquisition of items of equipment not listed in the approved grant budget, provided that the cost of each item is less than the sponsor’s threshold for prior approval. Any items costing more than the sponsor’s threshold require the prior approval of the authorized official at the sponsor. Some sponsors prohibit the purchase of equipment within the last six months of the project period, so a deviation from this restriction will also require prior approval from the authorized official at the sponsor.

International Travel: The sponsor’s terms and conditions must also be followed with regard to international travel. Requests for international travel should first be submitted with a detailed justification to OSP for submission in turn to the authorized official at the sponsor. Requests for international travel should be made at least 30 days in advance before the anticipated travel date.

Use of Unobligated Balance: Unless otherwise determined by the terms and conditions of the award, the authorized official at the sponsor will determine whether or not a balance at the end of one funded project segment can be carried forward to a new budget period. Prior written approval from the authorized official at the sponsor is required in these instances.

Approval of Subcontract and Sub-agreements not Included in Proposal: Subcontracts and sub- agreements that were not included in the proposal may require approval from the authorized official at the sponsor before executing a formal agreement and commencing work. The choice of a particular subcontractor must be documented with regard to the subcontractor’s qualifications to perform the work and the project’s need for such services.

Related Information

VU Office of Sponsored Programs