CHANGES IN PROJECT & BUDGET
In general, NIH grantees are allowed a certain degree of latitude to rebudget within and between budget categories to meet unanticipated needs and to make other types of post-award changes. Some changes may be made by the grantee only within limits established by NIH. Other changes require NIH prior written approval before modifying the budget or undertaking the activity in question. The degree of discretion permitted varies by type of grant, grantee, and coverage by, or participation in, a special initiative. The grantee-initiated changes that may be made under the grantee’s authority and the changes that require NIH approval are outlined below with respect to particular types of awards, activities, or recipients. In addition, individual awards my restrict grantees’ authorities to make budget and project changes without NIH prior approval. If NIH approval is required, it must be requested of, and obtained from, the designated NIH GMO in advance of the change or obligation of funds as specified below under “Requests for Approval.”
Changes in project or budget resulting from NIH-initiated changes are also discussed below.
PRIOR APPROVAL REQUIREMENTS
|NIH Prior Approval is Required for:||Circumstance:||NIH Prior Approval is Required for:||Circumstance:|
|Additional no-cost extension, extension greater than 12 months, or late notification of initial no-cost extension||All instances||Change of grantee organization status||All instances.|
|A&R (Alterations and Renovations)||Re-budgeting into A&R costs that would exceed 25 percent of the total approved budget for a budget period. If re-budgeting would not meet this threshold but would result in a change in scope. Any single A&R project exceeding $500,000.||Deviation from award terms and conditions||All instances. Includes undertaking any activities disapproved or restricted as a condition of the award.|
|Capital expenditures (construction, land, or building acquisition)||All instances. Also, any proposals to convey, transfer, assign, mortgage, lease, or in any other manner encumber real property acquired with NIH grant funds.||Foreign component added to a grant to a domestic or foreign organization||All instances.|
|Carryover of unobligated balances||If the NoA indicates that the grantee does not have the authority to automatically carry over unobligated balances.||Need for additional NIH funding||All instances, including extension of a final budget period of a project period with additional funds.|
|Change in scope||All instances||Pre-award Costs||More than 90 days before effective date of the initial budget period of a new or competing continuation award; always at the grantee's own risk.|
|Change in status of the PD/PI or senior/key personnel named in the NoA||Withdrawal from the project; absence for any continuous period of 3 months or more; reduction of the level of effort devoted to project by 25 percent or more from what was approved in the initial competing year award.||Re-budgeting funds from trainee costs||All instances.|
|Change of grantee organization||All instances.||Re-budgeting of funds between construction and non-construction work||All instances.|
Federal administrative requirements allow agencies to waive certain cost-related and administrative prior approvals; these are known as expanded authorities. In 2001, NIH extended expanded authorities to all NIH awards except for the provision to automatically carry over unobligated balances. Certain award instruments, grant programs, and types of recipients are routinely excluded from the authority to automatically carry over unobligated balances. This includes centers (P50, P60, P30, and others); cooperative agreements (U); Kirschstein-NRSA institutional research training grants (T); non-Fast Track Phase 1 SBIR and STTR awards (R43 and R41); clinical trials (regardless of activity code); and awards to individuals.
One or more of these authorities may be overridden by a special term or condition of the award. Grantees must review the NoA to determine if a particular authority is withheld for a specific grant.
Grantees must exercise proper stewardship over Federal funds and ensure that costs charged to awards are allowable, allocable, reasonable, necessary, and consistently applied regardless of the source of funds. NIH may disallow the costs if it determines, through audit or otherwise, that the costs do not meet the tests of allowability, allocability, reasonableness, necessity, and consistency.
Several authorities have specific deadlines for submission of reports or for timely notification to the NIH awarding IC. Grantees should be aware that any consistent pattern of failure to adhere to those deadlines for reporting or notification will be grounds for excluding that grantee from a specific authority.
|Grantee Authorities as NIH Standard Terms of Award||Exceptions|
|Carryover of unobligated balances from one budget period to any subsequent period||Centers (P50, P60, P30 and others), cooperative agreements (U), Kirschstein-NRSA institutional research training grants (T), non-Fast Track Phase I SBIR and STTR awards (R43 and R41), clinical trials, and awards to individuals, or if the NoA indicates otherwise.|
|Cost-related prior approval changes, including research patient care costs and equipment||The cost would result in a change of scope.|
|Extension of final budget period of a project period without additional NIH funds (no-cost extension)||The grantee has already exercised its one-time authority to extend the award for up to 12 months.|
|Transfer of performance of substantive programmatic work to a third party (by consortium agreement)||The transfer would be to a foreign component or it would result in a change in scope.|