Prior Approvals

After an award is made, changes resulting from circumstances not anticipated in the planning stages of the project are sometimes necessary. These changes can be programmatic or financial in nature. Some changes require the sponsor’s prior written approval, others may be authorized internally by Harvard. See below for examples.

Refer to the sponsor’s regulations and award documents and contact your ORA or SPA representative with specific questions regarding such changes. Requests to sponsors must be authorized by the school’s submitting office prior to submission to the sponsor.

Examples of programmatic and financial changes during the life of an award:

  • Changes in the scope of work (SOW)
  • Change of Principal Investigator or significant reduction of effort
  • Changes/additions to collaborating institutions/subcontractors responsible for carrying out a portion of the SOW
  • No cost extension of the budget or project period (extension of time without additional funds)
  • Re-budgeting.  Please follow the Rebudgeting Affecting Recovery of F&A (SPH) process for budgets that decrease F&A.
  • For federal awards, the OMB Circular A-110 grants permission to an awardee to re-budget, except where there is a change in the SOW or the need for additional funding
  • Non-federal awards may provide different thresholds for re-budgeting, for example by percentage or amount of deviation by budget category or line item, or stipulate that “substantial” deviation requires prior approval
  • Carry-forward of funds from one budget period into the next within a project period

Changes under Federal Demonstration Partnership (FDP) Awards

The Federal Demonstration Partnership (FDP) is a cooperative initiative among certain federal agencies and institutional recipients of research funds. The FDP developed standard Research Terms and Conditions (RTC) now in use by several federal sponsoring agencies. Visit the Research Terms and Conditions page on the NSF website for an explanation of each of the Research Terms and Conditions as well as a link to each participating federal agency’s specific RTC.

See the Prior Approval Matrix to identify how various federal agencies have implemented these Research Terms and Conditions and the need for prior sponsor approval.

Harvard has created a review process for changes that may be institutionally authorized, known as the University Prior Approval System, or UPAS. For project changes not requiring sponsor approval, a UPAS form (UPAS reference sheet) or request in GMAS should be completed and routed to your SPA office.

In order to change the managing Tub or Org of the fund, please see the Change of Tub or Org Process (SPH) for the step by step procedure.