UW Research

September 13, 2019

9.12.19 MRAM Follow Up – NSF Prior Approval?

Q: Is prior approval required from NSF if we budgeted for domestic travel but now need to carry out foreign travel (no change in scope of work)?

A: As long as otherwise allowable (e.g. reasonable costs, specific for project, project personnel are on travel status) you may carry out the foreign travel without getting NSF permission first. This is found in the PAPPG, Chapter II, C(2)(g)(iv) (Travel Costs), Chapter X(A)(3) (Prior Written Approvals), and PAPPG Appendix A (Research Terms and Conditions, Prior Approval matrix, adopted by NSF).

PAPPG, Chapter XI, Section F (Travel to Foreign Countries) sets out certain rules to follow with respect to foreign-flag carriers, economy class versus higher-class airfare, whether dependents can travel, etc.

There are some tips on documenting travel found on the Post Award Fiscal Compliance site. Keep in mind this documentation should explain how the travel is justified, both by destination and cost.

There are changes that do require prior approval by NSF, so if the foreign travel is incidental to these types of changes, NSF prior approval is needed. Examples:

  • Change in project direction, scope
  • Change in methods or procedures
  • Moving funds from participant support costs to other category
  • Adding a a subrecipient

Please keep in mind that though this cost change does not require prior approval, it deviates from the awarded budget, therefore if not mentioned in the next progress report and lacks justification documentation in the project file, it would pose a red flag upon audit.

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