It is not uncommon for the research plan of a project to be modified throughout the term of the award to ensure proper completion. As with any sponsored agreement issue, the ability to modify the project is determined by the terms and conditions of the agreement.
Federal awards, and Federal grants in particular, normally allow the University to internally approve certain budget deviations or other project changes. For example, Uniform Guidance includes a provision for grants that permits funding agencies to authorize UMBC, to allow:
- Expenditures up to 90 days before the official award start date
- A single no-cost extension of the award’s end date not to exceed 12 months duration.
All requests for budget or other project changes should be coordinated through OSP and be initiated by the Principal Investigator or by another appropriate person who possesses adequate technical knowledge. Since it is always possible for an individual award to have terms that are more restrictive than outlined above, each award must be reviewed; in certain circumstances, an agency may not unilaterally authorize pre-award costs or no-cost extensions. In such instances, OSP must seek approval directly from the funding agency.
The budget and other project changes described below not only require the approval of UMBC, they may also require approval by the funding agency:
- Purchase of any item of capital equipment with an acquisition cost of $5,000 or more and having a useful life of one year or more
- Purchase of any item of capital equipment that is general purpose in nature. Examples include computers, copy machines, furniture
- Alterations and renovations
- Travel expenditures exceeding the amount (generally 125%) indicated in the approved budget.
Funding agency approval is required whenever the change to a project involves an item that was not included in the budget as originally approved and funded by the awarding agency. Because each agency has its own set of rules, it may be necessary for OSP to write, or to co-sign, a letter to the agency requesting approval for the change. Questions about whether or not agency approval is required for specific changes should be directed to OSP.
The following budget or other project changes always require approval from the funding agency and, therefore, must be submitted to OSP for institutional endorsement:
- Any change in the scope of work or the subject of the investigation
- Any significant change in the level of effort devoted to the project by the PI or project director; typically, the variance is 25%.
- Any prolonged absence from the project, usually considered to be three months or more, by the PI or project director
- Any fixed price subrecipient arrangements made with another party to do a substantial part of the work of the project, when the arrangement was not included in the previously approved proposal budget
- Any re-budgeting of participant support costs or trainee support costs into another budget category
- Any budget changes affecting cost categories that are restricted in the sponsored agreement
- Transfer of the Principal Investigator to another institution
- Any reduction in the amount of cost sharing identified in the award budget.