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Expanded Authority / University Prior Approval System (UPAS)
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. Certain Federal agencies have implemented a mechanism known as Expanded Authority, by which these agencies have transferred to awardee institutions the authority to approve such changes.
Harvard's implementation of these authorities is described in the University Prior Approval System (UPAS).
Revised Terms and Conditions for NIH Awards
In October 1988, NIH implemented Expanded Authorities for its research grant mechanisms. In an effort to bring some consistency to the management of NIH's grant portfolio and to further streamline the administration of NIH awards, NIH is expanding these authorities (with the exception of automatic carryover of unobligated balances) to include all grant mechanisms.
Effective October 1, 2001 (awards issued on or after October 1, 2001), the authorities currently known as Expanded Authorities will become standard terms and conditions for all NIH grant awards.
Go to the full text of the NIH notice.
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 costs related and 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).
University Internal Approvals and Expanded Authorities
The Principal Investigator (PI) or Project Director (PD) may report deviations from budget and program plans, and request prior approvals from the University for any of the following:
- Pre-award Costs
Used 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/PD's school or department).
Harvard University Advance Account Policy
Advance Account Form
- Extension of Award Expiration Date
Used 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
Used 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)
Used to rebudget funds for foreign travel (Air Force only). Travel must be necessary for the research and conducted in accordance with federal regulations and University policy.
- Air Force Office of Scientific Research and
Office of Naval Research Subawards and Subcontracts
Used to rebudget funds to establish a subaward or subcontract with another institution (limited to AFOSR and ONR).
- National Endowment for the Humanities Stipends
and Travel
Used 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 Pre-award representative in advance to discuss your intentions.
- The signatures of the Principal Investigator/Project Director, Department
Chair/Designee, Dean/Designee, and Pre-award representative 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, your pre-award representative 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's signature on the request form.
- 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.
- 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 his/her pre-award representative 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% 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 expense categories.
- Subawards, transfers, or subcontracting out of a substantive programmatic portion of work, unless described in the application and funded in the approved award.
