Post-Award Changes and Approvals
Principal Investigators who want to make changes that deviate from the proposal originally approved by the Sponsor should refer to the specific terms of the award. In some cases, "internal" prior approval by the Office of Sponsored Programs (OSP) is sufficient, yet others may require the prior approval of the Sponsor as well. However, all budget related requests must be on a Budget Revision Prior Approval (BRPA) form.
Most sponsors require that they be informed of any significant changes. For Public Health Service grants, the following are usually considered a significant change and require the prior approval of the sponsor:
- significant rebudgeting action (more than 25%)
- changes in the objectives or scope of the project
- change of Principal Investigator or key personnel listed on the Notice of Award (NoA)
- change in grantee institution (transfers)
- purchasing equipment not originally budgeted
- change in the use of human subjects or animals
- adding a foreign component to a project
- incurrence of patient care costs not originally budgeted
- rebudgeting out of patient care costs
- transferring substantive programmatic work by contract
- rebudgeting from trainee costs
When the prior approval of the sponsor is required, the request should be made in writing to the sponsor and countersigned by OSP in advance of the change. Requests for retroactive approval should be avoided.
Changes such as No-Cost Extensions should be requested via the No-Cost Extension Request (NCE) form PRIOR to the expiration of the project with an explanation for the delay in research progress. Please contact OSP if you have specific questions.
Grants and contracts typically have requirements for programmatic performance reporting. Generally, progress reports are submitted on an annual basis for OSP approval and submission to the sponsor. However, the timing and frequency of reports is dictated by the terms of the grant or contract. Principal Investigators are responsible for submission of all technical reports and should become familiar with the terms of their grant or contract.
At the end of grants there is usually a reporting requirement as well. Detailed requirements are included as part of the Notice of Award (NoA) for the final year of the project. NIH typically requires three items within 90 calendar days of the last day of the final budget period - these are submitted via the eRA Commons:
1) a Financial Status Report - prepared and submitted by Grant Accounting after departmental confirmation;
2) a Final Progress Report - prepared, uploaded and submitted electronically by the PI, and;
3) a Final Invention Statement - filled out in the eRA Commons by the PI, then submitted to the NIH by OSP after patent information verification.
Unless otherwise indicated, the NIH requires submission of all items electronically via the eRA Commons. Just click on the Requires Closeout link for your specific grant within the NIH Commons website: https://commons.era.nih.gov/commons/index.jsp