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During the life of a federally funded grant award, it may become necessary to modify certain aspects of the original award. Such changes may involve rebudgeting of funds among expense classes or adjusting the length of a project period. Many federal agencies have transferred the authority to approve such changes to awardee institutions.
Harvard's implementation of these authorities is described in the University Prior Approval System (UPAS).
Background
Several years ago, the Federal Government streamlined the administration of sponsored research through issuance of two Office of Management and Budget (OMB) Circulars: A-21, "Cost Principles for Institutions of Higher Education"; and A-110, "Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Institutions."
These Circulars have provided more flexibility to institutions in the administration of grants. Federal agencies are authorized, at their option, to waive administrative prior written approvals required by OMB Circular A-110 and OMB Circular A-21. Harvard's UPAS system includes expanded authorities (e.g., approval of pre-award costs and no-cost extensions) and internal approvals (e.g., approval of equipment purchases or foreign travel).
UPAS applies to some federal grants and some cooperative agreements; contracts are excluded, as are non-federal awards (unless authorities are passed down under a federal prime award). Additional information is provided on eligible actions under federal grants through the UPAS.
University Internal Approvals and Expanded Authorities
The Principal Investigator (PI) may report deviations from budget and program plans, and request prior approvals from the University for any of the following:
- Pre-Award Costs
To create a sponsored research account for the purpose of incurring pre-award costs up to a maximum of 90 calendar days prior to award start date. Note, however, that any expenditures that precede the award are solely at the financial risk of the unit requesting these expenditures (i.e., PI).
- Extension of Award Expiration Date
To initiate a one-time extension of the award expiration date of up to 12 months (funding agency must be notified of extension at least ten days prior to original termination date). This extension may not be exercised merely for the purpose of using any unobligated balance.
- Adding Scientific or Special Purpose Equipment
To rebudget funds for the purchase of scientific or special-purpose equipment not identified in the approved budget. General-purpose equipment is not allowable unless used solely or primarily for the objectives of the sponsored project.
- Foreign Travel (Air Force Only)
To AFOSR and ONR Subawards and Subcontracts
To rebudget funds to establish a subaward or subcontract with another institution (limited to AFOSR and ONR).
- NEH Stipends and Travel
To rebudget funds for stipends and travel for conference participants, printing and publication costs (NEH only).
University Approval Procedures
- Internal prior approvals will be made on a University-standard UPAS form.
- In some exceptional circumstances and with reasonable justification, UPAS actions may be retroactively approved (i.e., after the funds have been reallocated in conformance with governing cost principles).
However, in all instances any request for a no-cost extension must be approved in advance of the original date of project termination, to allow adequate time for agency notification. It is advisable to contact your OSP representative in advance to discuss your intentions.
- The signatures of the Principal Investigator, Department Chair/Designee, Dean/Designee, and OSP are required to complete the UPAS approval.
For HMS, SPH, and DEAS the signature of the Dean/Designee is the authorizing signature (i.e., the date of this signature is the date the action is approved).
Following local approval, OSP will review HMS, SPH and DEAS actions to verify consistency with University policy. For other schools and departments, the approval is authorized on the date of OSP signature.
- For research and technical equipment purchases specifically included in the approved budget, UPAS approval is not necessary for the following:
- Change in vendor or model; or
- Change in acquisition price of 25% or less.
For equipment not specifically included in the approved budget, completion of the UPAS form is required. Equipment purchased with federal funds must be used for technical or scientific purposes and solely or primarily for the sponsored project.
- Prior approval requirements for domestic travel and for most foreign travel are deleted in accordance with the current issue of the federal cost principles outlined in OMB Circular A-21 and individual agency implementation of OMB Circular A-110. Specific agency requirements are identified on the reverse side of the UPAS form (e.g., Air Force).
Approval Required from the Funding Agency
The Principal Investigator of a federally sponsored project is required to report deviations from budget and program plans, and request prior approvals through OSP directly from federal awarding agencies (i.e., not via UPAS) for any of the following program- or budget-related reasons:
- Change in the scope or the objective of the project or program.
- Change in the Principal Investigator.
- Absence for more than three months or a 25 percent reduction in time devoted to the project, by the approved PI.
- Additional federal funding.
- Transfer of funds allotted for training expense (direct payment to trainees - stipend, tuition, fees) to other categories of expense.
- Subawards, transfers, or subcontracting out of a substantive programmatic portion of work, unless described in the application and funded in the approved award.
