#  Prior Approval & Other Requests 

 



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 Throughout the lifecycle of an award, modifications that differ from the original submitted proposal are often necessary. For both federal and non-federal awards, many of these changes require the sponsor's written prior approval before Harvard can process the change, as specified by the sponsor's terms and conditions. **Prior to requesting a change, please review the Notice of Award and applicable terms and conditions to understand any sponsor or award-specific requirements with respect to the allowability of a cost and/or prior approvals.**

 Requests for modifications that require sponsor approval typically also require that a request be entered in GMAS. Most prior approvals have a specific request type that should be utilized, but if there is no corresponding GMAS request type, the [Other request type](/other-request-type) can be used. The most common actions that typically require prior approval are:

- No Cost Extensions
- Early Terminations
- Pre-Award Expenditures
- Carry-forward
- Personnel/Research Team changes: 
    - Changes to Principal Investigator or Key Personnel participating in the project
    - Committed effort changes for Principal Investigator or Key Personnel
    - Absence for more than three (3) months, or a 25% or greater reduction in the time devoted to the project by the Principal Investigator or Key Personnel (applicable to federal awards)
- Budget Changes: 
    - Rebudgeting of funds
    - Changes to approved cost sharing
    - Rebudgeting of funds designated as Participant Support Costs to other budget categories
    - Capital expenditures for special purpose equipment on federal awards with a unit cost of $10,000 or more
- Programmatic changes: 
    - Changes in the scope or the objective of the project (even if there is no change to the budget) 
        - Please note: Equipment not approved in the original award with a unit cost above $25,000 may constitute a change in the scope of work. If a researcher is planning to purchase equipment over this threshold, please reach out to your OSP Awards Management Central Administrator to evaluate if the purchase will constitute a change of scope.
    - Addition of subagreements (foreign or domestic) at no additional cost
    - Subcontracting a substantive programmatic portion of the work, which results in a change in scope, unless described in the application and funded in the approved award budget
    - Collaboration (without an exchange of funds) or Subcontracting with a foreign entity

 Note on Prior Approvals for Federal Awards:

 Effective October 1, 2024, the OMB revised the Uniform Guidance to remove several items from the prior written approval requirements to reduce Federal agency and recipient burden. These changes are applicable to Federal awards issued after October 1, 2024, and amendments that issue additional funding to open awards after October 1, 2024. Unless the terms and conditions of the award or awarding federal agency otherwise prohibits or requires approval, these waived actions are:

- One-time extensions (with some exceptions, and we must notify sponsor) (§ 200.308)
- Unobligated balances and carryforward of unobligated balances to subsequent budget periods (§ 200.308)
- Certain costs associated with entertainment; memberships, subscriptions, and professional activity costs (Uniform Guidance § 200.454)
- The amount of fixed amount subawards that a recipient may provide with prior written approval from the federal agency increased from $250,000 to $500,000. (§200.333; 200.201)

 Please note, the [NSF Research Terms & Conditions](https://www.nsf.gov/awards/managing/rtc.jsp) (Research Terms and Conditions Appendix A - Prior Approval Matrix) are no longer applicable to awards made on or after October 1st, 2024.

 For questions about whether a modification requires prior approval or which GMAS request type to use, please contact your central office.



 



 

 See also:- [ Managing an Award ](/award-lifecycle/managing-award)