Funding News Edition: May 18, 2022 See more articles in this edition
After you receive a grant award, you may find that you need to alter aspects of your funded project. Before you proceed, keep in mind that you must get NIAID's permission before making certain changes.
If you fail to obtain this prior approval, your grant could receive special award conditions or enforcement actions such as cost disallowances, suspensions, or termination.
When Is Prior Approval Necessary?
As a principal investigator, you must request prior approval before taking actions such as:
- Modifying the scope of your grant
- Substantially changing or modifying Specific Aims [if this applies to you, contact your program officer (PO) about what constitutes “substantial”]
- Starting to work with vertebrate animals (VA) or human subjects (HS) when the peer-reviewed grant application did not cite their use in the work proposed nor incorporate the required HS or VA section
- Applying a new technology, e.g., changing the knockout mouse model from the one originally proposed to a completely new knockout model
- Adding a foreign component, defined as the performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended—see NIH’s definition of Foreign Component for examples of activities that may be significant
- Transferring a grant from one institution to another (see our May 4, 2022 Funding News article Changing Institutions? Know What To Do First)
For the complete list, see our Prior Approvals for Post-Award Grant Actions SOP.
Note that there may be items specific to your grant award for which you need prior approval, so read your most recent Notice of Award (NoA), which you can find in your eRA Commons account.
Be sure to pay attention to the terms of award in Section III of the NoA as well as critical NIAID special terms of award that, when added, are listed in Section III. For example, many cooperative agreement (U) awards require prior approval before you can carry over an unobligated balance into the next budget period; the NoA will list whether or not this applies to your U grant.
You can request some prior approvals using the Prior Approval Module in the eRA Commons. Find instructions at Seek Prior Approval (If Needed). Give yourself plenty of time to obtain NIAID approval for any change by making your request at least 30 days before you want it to take effect. To be safe, you may want to check with your grants management specialist (GMS) and PO about how much time you'll need for the type of change you're seeking to be approved. In the event your request is denied, the GMS will notify the grantee in writing.
When Is Prior Approval Not Necessary?
You can make some changes without first getting NIAID's permission. For instance, you can extend a project period for up to 12 months without additional funds, i.e., request a no-cost extension if you have a grant with an award period of five years or less.
Find a complete list of other authorized self-administered award changes in Section 8.1.1 NIH Standard Terms of Award in the NIH Grants Policy Statement. This authority may be taken away only by NIAID and would be added as a term and condition on the NoA.
To Get Prior Approval or Not
If you're unsure whether prior approval is required, it's best to err on the side of caution and contact your GMS and PO. Additionally, see Section 8.1.2 Prior Approval Requirements in the NIH Grants Policy Statement.
For more information, go to Grantees Can Take Many Actions Independently in Changes to Project or Budget.