Most requests for project changes are routed through Harvard's Grants Management Application Suite (GMAS), but not all require school and department signature. The Roles and Responsibilities Matrix is a quick reference guide to who initiates requests and how they are approved.
Many changes to the terms and conditions of awards require prior approval by the sponsor. In some cases, Harvard has been granted “expanded authorities.” In these cases, sponsor prior approval is waived and Harvard is only required to notify the sponsor.
Approval requirements for most federal agencies can be found in the FDP Prior Approval and Other Requirements Matrix posted by the National Science Foundation. Note that rules for project changes vary between federal agencies non-federal sponsors. When making changes to a foundation grant or a grant from a federal agency that is not listed in the FDP Matrix, be sure to refer to sponsor policy.
Commonly Requested Project changes
- Revised Budgets
- No-Cost Extensions
- Supplemental Funding
- Substantive Project Changes
- Transfer of Grant to or from Harvard
- Equipment not in original budget
- Subcontract not in original budget
Most sponsors understand the need for a degree of flexibility the proposed budget and allow Principal Investigators (PIs) to make changes without agency approval as long as the scope of work is not affected. However, certain types of changes restricted, and prior approval must be obtained, either by contacting the sponsor directly (rare) or by exercising the university’s expanded authorities.
Prior approval should be sought if the rebudgeting will involve moving substantial sums between budget categories. For example, the NIH Grants Policy states that “significant rebudgeting occurs when expenditures in a single direct cost budget category deviate (increase or decrease) from the categorical commitment level established for the budget period by 25 percent or more of the total costs awarded. The base used for determining significant rebudgeting excludes the effects of prior-year carryover balances but includes competing and non-competing supplements. Significant rebudgeting does not apply to modular grants.
Prior approval must be obtained directly from the sponsor for a change to the scope of work —regardless of the amount rebudgeted.
Once the approvals are confirmed, the record must be updated in GMAS. Budgets can be directly modified in GMAS. Updating budget information for a project is essential for comparing actual expenditures with amounts budgeted.
If more time is needed to complete the sponsored project, the PI can apply for an extension of time without additional funding known as a “no-cost extension (NCE).”
Extensions on federal projects can often be approved by OSP under expanded authority. The justification on the request must explain in detail why more time is necessary to complete the proposed work. The agency must be notified of NCEs by OSP 10 business days prior to the original termination date. Expanded authorities may be used to extend the award only once; if a further time extension is needed, agency approval must be sought.
NCE requests to non-federal sponsors, or second requests to federal agencies must be made well in advance of the project end date using the procedure outlined by the sponsor. It is usually best to request a NCE about 90 days in advance of a project end date. Most sponsors require that the PI justify the request, set forth the amount of award funds remaining and provide a budget showing how those funds will be used during the extension period. Requests for NCEs are administered through GMAS and require only Department and OSP approval.
Supplemental Funding Requests
Requests are submitted to sponsors by OSP, usually in the form of a short proposal outlining the work to be done and the need for additional funds. A budget and budget justification must be attached showing how the additional funds will be used. The supplement request is submitted through GMAS and approved by the Department, FAS and OSP in the same manner as any other proposal.
Substantive Changes to Proposed Research
Significant changes to the research from what was proposed and approved by the sponsor typically require sponsor approval. PIs are therefore advised to contact their Program Officers as soon as possible in the following situations:
Changes in Objectives or Scope- Neither the phenomena under study nor the objectives of the project stated in the proposal should be changed without first obtaining sponsor approval. Such changes should be proposed to the sponsor in writing and countersigned by an Authorized University Signatory at OSP.
Changes in Research Methods -The PI may wish to pursue interesting and important leads that arise during the conduct of a research project, or to adopt an alternative approach that appears to be a more promising means of achieving the objectives of the project. PIs should contact their Program Officers in these situations to ascertain whether formal approval is necessary.
Significant Changes, Delays, or Events of Unusual Interest- It is appropriate for the PI to contact the Program Officer when he/she becomes aware of any delays or adverse conditions that will affect the ability to attain the objectives of the project or to meet any time schedules outlined in the original proposal. The Program Officer should also be informed when any events of unusual interest occur during the course of the project.
Change of PI -The sponsor’s decision to support or not to support a proposal is based, to a considerable extent, upon its evaluation of the PI’s knowledge of the field of study and ability to conduct the project. Therefore, sponsors expect to be notified formally if the PI devotes substantially less effort to the work than anticipated in the approved proposal, leaves the University, or otherwise relinquishes active direction of the project.
Absence of PI - If the PI, or other key personnel named in the notice of award, will be away from the project for a continuous period longer than three months, arrangements for interim oversight of the project should be made and a request for approval be sent to the Grants Management Officer of the agency. This information should also be provided to the Program Officer as far in advance as possible. An Authorized University Signatory at OSP must also endorse these requests. If the arrangements are not satisfactory to the sponsor, the award may be suspended or terminated.
Transfer of Grant to or from Harvard
Sponsors require that the award be properly closed out at the PI’s prior institution before giving approval to transfer the award to the new institution. The prior institution must provide a final financial accounting with which the sponsor concurs and then formally relinquish the grant. The receiving institution may need to provide a revised budget. If Harvard is the receiving institution then the Department should initiate the GMAS request for the "new" grant. The award balance is then transferred to the new institution. It is the PI’s responsibility to notify his/her Program Officer as soon as possible to alert them to any changes of this nature. No transfers will be made until the PI has completed all reporting requirements.
A transfer of a grant may involve the transfer of equipment purchased with sponsor funds. The transfer of equipment may be accomplished as part of the relinquishment of the grant, subject to sponsor approval.
In many cases, grants to be transferred to Harvard from other institutions will have a lower Facilities and Administrative (F&A) rate than Harvard’s negotiated federal rate. In some circumstances Harvard may choose to accept the previously approved F&A rate, with the understanding that this lower rate will be allowed only until the next competing continuation or renewal phase.
Note: Pending proposals require formal transfer of ownership when the PI moves from one institution to another before a funding decision has been made. In this situation, the PI’s previous institution also relinquishes ownership of the proposal to the sponsor. The new institution then submits a revised budget (using its F&A rate), budget justification, and other pertinent forms as requested by the sponsor. In some cases the agency may require the PI to resubmit the proposal in its entirety.
Equipment Not in the Original Budget
Agency approval is not usually necessary when the PI of a federal award wishes to purchase a piece of equipment (see: Equipment Management for definition) not originally identified in the budget. Such requests are submitted via GMAS and may be approved by OSP under expanded authorities. Requests require a scientific/programmatic rationale for the purchase, a cost breakdown, and, if possible, vendor quotes.
Prior approval is not required for a change of vendor or model for equipment included in the approved budget, nor for a change of 25% or less in the acquisition price of approved equipment. Purchasing equipment at the end of a project period is difficult to justify and will not normally be permitted.
Subcontracts Not in the Original Budget
In general, sponsors must approve subcontracts not identified in the original budget. Appropriate paperwork from the proposed subcontractor must be included: a cover sheet and necessary representations and certifications signed by the subcontractor’s authorized institutional representative, a statement of work, and a budget and budget justification. The Harvard PI should supply a cover letter explaining the need for the subcontract.