Ask Permission, Not Forgiveness, for a Change in Scope

Funding News Edition: January 21, 2021
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Amid the pandemic, we’ve seen an uptick in principal investigators making changes to the scope of research conducted under their NIAID awards. Such changes are permissible so long as the grantee seeks and NIAID confirms prior approval for the change in scope. Making a change in scope without NIAID’s prior approval risks enforcement actions.

Below, we define “change in scope” and provide instruction on how to request NIAID’s prior approval.

What Constitutes a Change in Scope?

A change in scope is a change in the direction, aims, objectives, purposes, or type of research training, identified in the approved project. Examples include:

  • Changing the Specific Aims that were approved at time of award
  • Shifting the research emphasis from one disease area to another
  • Changing any aspects of research involving vertebrate animals or human subjects
  • Changing the principal investigator

Several other actions may indicate a change in scope, depending on the circumstances. Determine whether the following actions necessitate an official prior approval request by conferring with NIAID staff beforehand:

  • Applying a new technology, e.g., changing the knockout mouse model from the one originally proposed to a completely new knockout model
  • Changing key personnel
  • Rebudgeting funds in or out of a budget category by more than 25 percent of the total costs of the award (in the absence of a specific waiver allowing you to rebudget)

For a list of all actions that could constitute a change in scope, see Section of the NIH Grants Policy Statement

How To Request Prior Approval for a Change in Scope

Before implementing a change in scope, you need to request and receive NIAID’s written prior approval. We highly encourage you to discuss the possibility with the assigned program officer before submitting the request. Do so by following the process detailed at Prior Approvals for Post Award Grant Actions SOP.

Have your institution’s authorized organization representative (AOR) send a prior approval request to your award’s assigned grants management specialist, copying the assigned program officer, at least 30 days before the planned use of funds.

The email should include:

  • The grant number in the subject line
  • The principal investigator’s name, title, organization, telephone and fax number, and email address
  • The AOR’s name, title, organization, telephone and fax number, and email address
  • Justification for the proposed change
  • SF 424 RR Guide Modified Scope Template, completed and attached that includes:
    • Modified Project Summary/Abstract Section—If the abstract will be modified, provide the modified abstract in this section. If the abstract will not be modified, state “none” instead.
    • Modified Specific Aims Section—If one or more Specific Aims will be modified, list the complete Specific Aims modification(s) in this section; up to one page is recommended. If the Specific Aims will not be modified, state “none” instead.
    • Modified Public Health Relevance Section (Project Narrative)—If the project narrative will be modified, provide two or three sentences to modify the Project Narrative. If the project narrative will not be modified, state “none” instead.

Submitting a request for a change of scope does not guarantee NIAID will approve it. Again, discuss your situation with the assigned program officer before submitting the prior approval request.

Changes Listed in Progress Reports

To be clear, the Research Performance Progress Report (RPPR) is not a vehicle by which you ask NIAID to approve past or planned changes in scope; completing Section F. Changes of the RPPR is not a substitute for properly requesting prior approval for a change in scope. Informing NIAID through the RPPR of a change of scope that has already occurred, and for which NIAID did not provide prior approval, may result in cost disallowance or other enforcement measures listed in Section 8.5 of the NIH GPS.

NIAID program and grants management staff review annual progress reports in part to confirm that grantees have remained within scope.

To learn more about managing your grant, including reporting requirements and actions you can take with and without NIAID’s prior approval, read the sections Grantees Can Take Many Actions Independently and Some Actions Require Our Approval on our Changes to Project or Budget webpage.

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