OSP | Award Modifications

Change of Principal Investigator or Key Personnel

During a sponsored project, circumstances may arise warranting the designation of a new principal investigator/key personnel. The appointment can be made only with the approval of the teaching unit head, school/college dean, Assistant Provost, and sponsor. The request for designation of a new principal investigator/key personnel may require a stated reason for such a change with a new curriculum vitae of the proposed principal investigator/key personnel. Specific requirements and/or additional information may be required by the sponsor.

Transfer of Sponsored Awards

From Another Institution

A new AU faculty/staff member coming from another institution may wish to transfer his/her sponsored award to American University. Generally, such transfers require the approval of both the previous institution and the sponsoring agency. To initiate the transfer process, a new or revised proposal is prepared and sent through OSP's normal routing process. For additional information on the transferring of an award from another institution, the assigned OSP pre-award staff member should be contacted.

To Another Institution

An AU principal investigator who is transferring out of the university may wish to continue his or her sponsored project at a new institution. A request to transfer the sponsored award to a new institution must proceed through OSP, with the consent of the PI’s teaching unit head, the school/college dean, and the approval of the sponsoring agency. Approved transfers occur only after a final accounting and release from Grants and Contracts Accounting (GCA), certifying the amount of funds remaining available to transfer.

If American University elects to retain the sponsored award, a new principal investigator will be nominated to replace the departing principal investigator, upon confirmation and approval of the teaching unit heads, school/college dean and sponsoring agency..

No-Cost Extensions – Click here to obtain the form

Purpose: To request an extension of time beyond the current ending date of an award.

Occasionally, the completion of a sponsored project/program may require more time to complete. If no additional funds are necessary to complete a sponsored project/program during the proposed extension period, a no-cost extension may be requested from the sponsor. PI’s seeking a no-cost extension should notify OSP at least 45-60 days (or other advanced period as required by the sponsor) prior to the project/program expiration date.

Most Federal grants and cooperative agreements issued under Research Terms and Conditions allow for a single grantee-approved no-cost extension. In these instances, OSP on behalf of the University/PI must notify the Federal agency of its intention to extend the end date of the award. For all projects that do not allow grantee-approved no-cost extensions, or when the grantee-approved no-cost extension has already been exercised, a request must be submitted by the University to the Sponsor for approval to extend the period of performance of the project. In cases where a notification or request can be submitted through a Sponsor’s post-award management system (e.g. NSF FastLane, NIH eRA Commons, etc.) the No-Cost Extension Request Form does not need to be completed.

When seeking a no-cost extension, the PI is required to provide written justification for the request by completing the No-Cost Extension Request Form. The justification should contain all of the components (i.e. the reason for needing a no-cost extension/an account of award funds spent and unobligated to date, etc.) that are required by the sponsor. OSP will advise the PI of all the components that must be within the written request as well as submit the request on behalf of the PI and American University.

Sponsors expect that key personnel will continue to expend the same effort on the project during the no-cost extension. Should the effort of any key personnel be anticipated to decrease during the no-cost extension period, it must be fully disclosed at the time the no-cost extension is requested or, in the case of grantee-approved no-cost extensions, at the time the Federal agency is notified of the desire to extend the period of performance.

Please be advised that remaining funds are generally not a sufficient justification for requesting a no-cost extension if the sponsored project/program has already been completed.

As a general guideline, the following are minimum requirements for requesting a no-cost extension:

  • The project is not completed and additional time is needed to complete the project;
  • There are legitimate reasons for delays or reasons why the project has not been completed as expected and a reasonable plan for completing the project;

Changes in Scope of Work

Changes to the scope of work must be approved by the sponsor. PI’s should consult with OSP when seeking approval from the sponsor when seeking changes to the scope of work.

It may be difficult to determine when scope of work changes requires sponsor’s approval. Principal Investigators should consult with OSP when in doubt. The following are examples of scope of work changes that generally require sponsor’s approval:

  • Change in PI effort
  • Changes in planned equipment purchases;
  • Changes in number of human or animal subjects;
  • Major changes in staffing, travel plans, etc.

All changes to the scope of work approved by the sponsor must then be routed and approved by the PI’s department head/school/ college dean. Because changes to the scope of work differ from the original scope of work that was institutionally approved, sponsored approved changes to the scope of work would require approval by the PI’s department head/school/college dean. OSP will facilitate obtaining those approvals.

Re-budgeting

Changes in sponsored award budgets are generally guided by the terms and conditions of the sponsored award. Some sponsors allow “insignificant re-budget changes” to be done without their approval. In this case, the PI is free to re-budget accordingly. When the PI has the ability to re-budget without prior approval, a revised project brief is not required.

Significant budget changes from one budget category/line item to another generally require the sponsoring agency’s approval. As a rule of thumb, significant re-budgeting is defined as a transfer of 25% or more from one budget category/line item to another, however “significant re-budget changes” are often defined in the terms and conditions of the sponsored award. OSP will contact and obtain the sponsor’s approval prior to authorizing significant re-budgeting changes.

In those instances where re-budgeting requests can be submitted through a sponsor’s post-award management system (e.g. NSF FastLane), no additional paperwork is necessary. In all other instances, a letter will need to be drafted by the Principal Investigator/Project Director (PI/PD) that explains the re-budget request and the affect it will have on the project. A revised budget will need to accompany the letter. This letter should be signed by the PI/PD and counter-signed by the Office of Sponsored Programs (OSP) or the Vice Provost for Research and Dean of Graduate Studies (VPRGC). OSP will forward the request to the sponsor for action. When significant re-budgeting changes are approved by the sponsor; OSP will create and distribute a revised project brief.

If you are unsure whether or not re-budgeting is allowed under a sponsored project, please contact your assigned OSP staff member for guidance.

For general guidance on re-budgeting for federal sponsored projects refer to OMB Circular A-110, Section 25 - Revision of Budget and Program Plans as listed below.

OMB Circular A-110, Section 25

http://www.whitehouse.gov/omb/circulars/a110/a110.html#25

Revision of budget and program plans.

Carryover/Carry Forward Requests

Sponsor policies vary regarding the handling of unspent funds at the end of a budget period. The terms and conditions of the sponsored award generally specify the treatment of unspent funds. When the terms require prior approval to carry over funds from one budget period to the next, the

PI/PD is required to submit a written request/justification to OSP. OSP will then submit the carry over request to the sponsor. Most sponsors require the request to include an explanation of why such unspent funds exist and how they will be used during the next budget period. A revised project brief will be created by OSP upon the sponsor’s approval, and GCA will carry over funds from one budget period to the next. A revised project brief will not be created by OSP when the award terms and conditions authorize funds to be carried over without the sponsor’s approval. Upon request, GCA will carry over funds from one budget period to the next.

Request for Supplemental Funds/Additional Funding

Requests for supplemental/additional funds should include a budget showing how the funds will be spent and an explanation of why they are needed and relevant to the sponsored program/project. Such requests must be approved by the PIs/PDs departmental/school/college head and submitted through OSP. OSP will submit the request for supplemental/additional funds to the sponsor for review and approval. If approved, OSP will develop and distribute a project brief advising of the approval for supplemental/additional funds. Please be advised that some sponsors require supplemental/additional funds to be tracked and managed separate from the original funds that were awarded. In that event, OSP will request a separate account from Grants and Contracts Accounting (GCA) for the supplemental/additional funds.

Project/Program Cost Overruns

Since principal investigators serve as the budget managers for sponsored projects, it is their responsibility to keep the budget in order and within limits. Cost overruns will be charged to the principal investigators’ department/school/college.

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