Award Changes

Questions and Attachments

There are a few questions and attachments that your OSP reviewer will need when you submit a Modification Request for an amendment on a non-federal and industry sponsored clinical trial agreement.

Provide responses to these questions in the comment section:

• What is the primary purpose of the Amendment?
• Provide the best, current sponsor contact information.
• Does the amendment add or subtract funding (a decrease or increase the amount)? If yes,  indicate the modified sponsor total for all spending periods.
• Does this Amendment cause a budget change of more than 10% or are there new charges? If yes, then the Amendment must be reviewed by the UW Clinical Trials Office – CTO. We must have their review/approval before signing the agreement.

Attachments as applicable:

• Amended Scope of Work
• Updated Protocol
• Current IRB approval
• Draft CTA amendment
• Sponsor/CRO correspondence
• CTO summary review & approval – if the budget changes by 10% or there are new charges.
  • If still pending, state this in the comments.

Carryover

Carryover (aka Carry Forward) is when the balance of unused funds at the end of a Budget Period transfers to the following Budget Period. Some sponsors allow automatic carry forward of funds from year to year, others require prior approval.

Carryover requests that require prior approval must be coordinated through OSP.

Request Carryover

To request prior approval for carryover, create a SAGE Modification Request (OSP/GCA).

Select Funding & Budgeting Change MOD, indicate this is a Carryover request in the comments, and provide OSP with:

• Concurrence letter attached to Modification Request in SAGE detailing the reason for unused funds and how those funds will be spent in support of the project for OSP signature and submission to the sponsor
• Why did the awarded budget not match expenditures on the award?The amount of funds to be carried forward and an explanation of unobligated balance
• Attach an exported excel version of the SAGE Budget or Create a budget snapshot in SAGE Budget and include a link to that snapshot in the comments field of the Modification Request
  • This detailed SAGE Budget Worksheet needs to include the carryover amounts according to how they are going to be spent
• For budget changes to an existing award line, include the UW Award Line Worktag(s) (GRXXXXXX) # along with the request for budgetary changes so GCA will know which Grant ID changes should be applied to.
• A copy of the carryover budget for submission to sponsor (according to sponsor requirements)

Automatic Carryover?

If you are waiting for an award modification from the sponsor to be fully executed and the terms & conditions of the award indicate Automatic Carryover, you should request a Temporary Internal Extension. Please review guidance for Temporary Internal Extensions.

Addition of Equipment - Sponsor Approval

The purchase of equipment typically results in rebudgeting and may result in a change of scope for the project. Many sponsors require that prior approval is requested before making this significant purchase, if not earlier included in the approved budget.

• Create a SAGE Modification Request (OSP/GCA), select Funding and Budgeting Change, indicate Addition of Equipment in the comments field
• Attach a completed concurrence letter, and supporting sponsor required documentation, such as a copy of the quote from the equipment vendor/manufacturer
• Attach an exported excel version of the SAGE Budget or Create a budget snapshot in SAGE Budget and include a link to that snapshot in the comments field of the Modification Request
  • For budget changes to an existing award line, include the UW Award Line Worktag(s) (GRXXXXXX) # along with the request for budgetary changes so GCA will know which Grant ID changes should be applied to

Deobligations

Deobligations may also be known as funding decreases on an award. Sponsors typically issue a deobligation to reduce award amounts for the following situations:

• Award will end early (e.g. early termination)
• UW did not spend & draw down / invoice for the full award amount by end of project period
• Sponsor decides to reduce award amount related to project needs

What to do:
Create a SAGE Modification Request (OSP/GCA), select Funding and Budgeting Change, indicate this is for a Deobligation in the comments, and provide the following with your MOD in SAGE:

• Deobligation or revised award notification from the sponsor indicating reduced award amount
• PI confirmation accepting award amount reduction
  • This can be in the form of the PI included as an Ad Hoc Approver on the MOD or an email with PI approving the deobligation attached to the Modification Request
• Attach an exported excel version of the SAGE Budget or Create a budget snapshot in SAGE Budget and include a link to that snapshot in the comments field of the Modification Request that reflects the reduced award (if not provided as part of the award modification).
  • GCA needs to know line items being impacted by reduction to complete the changes to the award in WD Finance.
  • Indicate the UW Award Line Worktag(s) (GRXXXXXX) # along with the request so GCA will know which Grant ID changes should be applied to.

If an active subaward is affected, you will also need to submit a subaward modification request.

If the deobligation is accompanied by early termination, also select the End of Award Change category.

Other Funding and Budgeting Changes

If you need to request other funding & budgeting changes that require prior approval and that do not otherwise fall into a specific type of Funding and Budgeting Changes, provide an explanation in the comments and attach supporting documentation to the Modification Request in SAGE such as concurrence letter or award modification received from sponsor.

• Attach an exported excel version of the SAGE Budget or Create a budget snapshot in SAGE Budget and include a link to that snapshot in the comments field of the Modification Request.
• For budget changes to an existing award line, include the UW Award Line Worktag(s) (GRXXXXXX) # along with the request for budgetary changes so GCA will know which Grant ID changes should be applied to.

Payment Schedule Change

These requests are submitted on a Modification Request (OSP/GCA).

Rebudgeting

Sometimes the approved award budget is not consistent with actual project needs. Many sponsors allow reasonable budget revisions without prior approval. Review the award and sponsor guidance to ensure compliance with rebudgeting requirements. Some sponsors require prior approval for budget revisions.

• Attach an exported excel version of the SAGE Budget or Create a budget snapshot in SAGE Budget and include a link to that snapshot in the comments field of the Modification Request.
• For budget changes to an existing award line, include the UW Award Line Worktag(s) (GRXXXXXX)# along with the request for budgetary changes so GCA will know which Grant ID changes should be applied to.

Rebudgeting – Sponsor Approval Required

When prior sponsor approval is required you will need to submit the request on a SAGE Modification Request (OSP/GCA).

• Create a Modification Request (OSP/GCA), select Funding and Budgeting Change, and within the comments  indicate it is a rebudgeting request
  • Detail the need for the rebudget request and reflect how the rebudgeting will support the project: If no sponsor system of submission involved, attach a completed concurrence letter to the Modification Request along with any other supporting sponsor required documentation
  • If a sponsor uses an electronic system for submission of the request, use that system to prepare and forward your request to OSP (AOR).
• Attach an exported excel version of the SAGE Budget or Create a budget snapshot in SAGE Budget and include a link to that snapshot in the comments field of the Modification Request.
• Include the Grant ID# along with the request so GCA will know which Grant ID changes should be applied to.

Rebudgeting when Prior Sponsor Approval NOT Required

This includes rebudgeting to transfer funds between award lines. Review GCA guidance on Modifications.
When sponsor approval is not required:

• Create a Modification Request (GCA only), select Funding and Budgeting Change, and indicate Rebudgeting in the comments
• Update awarded budget and worksheets in SAGE Budget
• Attach an exported excel version of the SAGE Budget or Create a budget snapshot in SAGE Budget and include a link to that snapshot in the comments field of the Modification Request.
• Include theUW Award Line Worktag(s) (GRXXXXXX)# along with the request so GCA will know which Grant ID changes should be applied to.
• GCA encourages including their optional GCA Modification Checklist along with your GCA only Award Modification requests.
• Follow your departmental/campus unit guidance for including Ad Hoc approvers your unit requires for budget changes.

Related Resources:

• Grant and Contract Accounting: Rebudgeting funds on grants and contracts
• Post Award Fiscal Compliance: more information on rebudgeting

Subaward Addition / Add Subrecipient

Create a SAGE Modification Request (OSP/GCA), select Funding and Budgeting Change, indicate Subaward Addition in the comments and:

• Attach subaward documentation consistent with GIM 7 to the Modification Request
• If sponsor approval is required, attach a concurrence letter for submission to the sponsor along with any other sponsor required documentation to the Modification Request
• Update a SAGE Budget worksheet for the new subaward on the Awarded SAGE Budget
• Attach an exported excel version of the SAGE Budget or Create a budget snapshot in SAGE Budget and include a link to that snapshot in the comments field of the Modification Request.

Supplement

A sponsor may provide awards funds incrementally throughout the project.

Supplemental funding is processed under a SAGE Modification Request (OSP/GCA) select Funding and Budget Change.

Note: Award Setup Requests are not used for supplemental funding.

Applying for supplemental funding? When supplemental funding requests to a sponsor require a proposal application, complete an eGC1, note, ASR’s are not used for these.

Often OSP receives supplements from the sponsor and will create the initial Modifications in SAGE and route back to campus for completion.

Some things to keep in mind when creating or completing a MOD for a Supplement:

• Supplemental funding requires a SAGE Budget Worksheet.
  • Attach an exported excel version of the SAGE Budget or Create a budget snapshot in SAGE Budget and include a link to that snapshot in the comments field of the Modification Request.
  • For budget changes to an existing award line, include the UW Award Line Worktag(s) (GRXXXXXX)# along with the request for budgetary changes so GCA will know which Grant ID changes should be applied to.
• Non-fiscal compliance changes?
  • Provide information about the changes and include relevant approval dates and protocol numbers & attach any relevant compliance documentation to the Modification Request
    • Review more information on Communicating Compliance Information
  • The PI, Personnel & Organizations page of the original eGC1 should be updated, if necessary. Investigators should update their SFI disclosures if they have not renewed their SFI or if there is new or updated SFI to disclose.
• If the supplement is also an extension, both Funding & Budget and the & Schedule Change should be selected as MOD types in SAGE.
• Indicate the MOD is for a Supplement in the comments

Cost Center Change

These requests are submitted on a Modification Request (GCA only), select Other Changes.

Federal Data Repository Access & Submission

When you are accessing or submitting data to a Federal Repository such as dbGaP, NIAGADS, CMS, and are required to complete a Data Submission Agreement (DSA), Data Access Request (DAR) or Data Use Certification (DUC) you will need to submit an Award Modification Request in SAGE to OSP/GCA and select Other Changes.

• Attach the completed Federal Repository form.
• Include a comment on the Modification that indicates what you are requesting.

NOTE: Before submitting human subjects datasets to repositories, consult with the Human Subjects Division hsdinfo@uw.edu

Progress Report - RPPR - Submission

A Modification is not needed for any of the following progress report submissions:

• Sponsor allows direct submission of the progress report by the PI
• NIH: SNAP eligible Annual, Interim, or Final RPPRs
• NIH: Interim and Final RPPRs
• Fred Hutchinson Cancer Center (FHCC)
  • FHCC does not require OSP signature on progress report materials / Letter of Intent for non-competing years

You will need a SAGE Modification Request (OSP/GCA) for these progress report submission requests as follows:

• NIH non-SNAP Annual RPPR
  • Review How do I know if an award is SNAP eligible?
• Some federal flow-through awards, if the pass-through entity requires a signature or a Letter of Intent
  • Don’t assume they require a signature
  • Confirm with the pass-through entity before routing a Modification

What to do

• Create a Modification Request (OSP/GCA), select Other Changes, within the comments indicate this is for an RPPR
• If no sponsor system of submission involved, attach the progress report or other sponsor required documentation for progress report submission
• If a sponsor uses an electronic system for submission of the request, use that system to prepare and forward your request to OSP (AOR). An example is eRA Commons (NIH). Attach a copy with your Modification Request
• An updated SAGE Budget Worksheet is not needed at this time
• The PI, Personnel, & Organizations page of the original eGC1 should be updated, if necessary
• Investigators should update their SFI disclosure if they have not renewed their SFI or if there is new or updated SFI to disclose. This is checked later at the time supplemental funding is processed

Restriction Release

Award terms and conditions may place restrictions on some or all of the funding before it can be spent. Some restrictions require prior sponsor approval before the restriction can be lifted. All restricted funding must be managed with internal controls at the UW.

When a sponsor restricts funds, OSP will include reference to the restriction in a comment on the Award Setup Request or the Modification Request.

Requesting Funding Restriction Removal: Prior Approval Required

Review your award and comments on your Award Setup Request or Modification to determine if prior approval from the sponsor is required to lift funding restrictions.

Submit requests for prior approval via a SAGE Modification Request (OSP/GCA), select Other Changes, and provide:

• Description of the request
• Explanation of how requirements have been met to release the restriction
• Supporting documentation attached to the MOD that reflects requirement has been met (e.g. protocol approval)
• After sponsor prior approval is obtained, OSP will approve the MOD and send it to GCA

Request Removal of Funding Restriction when Prior Sponsor Approval is NOT Required

Requests to remove spend restrictions on an award when prior approval is not required are submitted on a SAGE Modification Request (GCA only), select Other Changes, indicate request to remove funding restriction in the comments.

GCA encourages including their optional GCA Modification Checklist along with your GCA only Award Modification requests.

Award Line Type

Submit requests to change award line types on a SAGE Modification Request (GCA only), select Programmatic Changes, indicate Award Line Type Change request in the comments.

GCA encourages including their optional GCA Modification Checklist along with your GCA only Award Modification requests.

Key Personnel Changes - Includes PI

Follow the instructions for each of these types of Key Personnel changes.

Change of PI – Campus Steps

When the PI originally named on a proposal needs to change to another UW PI after an award is made, there are a few things that need to happen. Not only is prior sponsor approval required, the UW needs the new PI to provide specific assurances, and the unit Chair & Dean also need to provide their concurrence.

These instructions explain what to do when a change of PI is required once an award has been made to UW.

• Follow Preliminary Steps to Change a PI instructions and complete the Change of PI form
• Update eGC1 PI, Personnel, & Organizations page: Change the Principal Investigator
  • Update any other Personnel and/or Investigator Status for the project if applicable. If other Key personnel are changing, sponsor prior approval is also required, follow steps for Key Personnel changes.
• Submit a SAGE Modification Request (OSP/GCA), select Programmatic Change and attach:
• Completed Change of PI Request form
  • Proof of Sponsor’s authorized representative approval or If sponsor approval is outstanding, attach request drafted to the sponsor on the new PI’s campus unit letterhead, signed by the new PI and the Chair/Unit Lead for OSP concurrence
  • Documentation reflecting the new PI’s suitability for the role (such as their Biosketch and Other Support) as required by the sponsor
  • Other supporting material as required by the sponsor
• Make any budgetary changes on the award budget in SAGE Budget as needed and select Funding and Budgeting Changes along with Programmatic Change, and include a comment that this request is for a change of PI
  • If the budget needs changes:
    • Attach an exported excel version of the SAGE Budget or Create a budget snapshot in SAGE Budget and include a link to that snapshot in the comments field of the Modification Request.
    • For budget changes to an existing award line, include the UW Award Line Worktag(s) (GRXXXXXX)# along with the request for budgetary changes so GCA will know which Grant ID changes should be applied to.
• Provide details on changes to the scope of work that result from personnel changes
• Include an explanation of the change in MOD Comments field

A change of PI will be reflected on the Award in Workday after OSP receives sponsor approval and GCA has processed the Request in Workday Finance. Review requirements for a change of PI when Human Subjects or Animal Research is involved.

After OSP receives the authorized sponsor representative’s approval of the change, OSP will send the modification request to GCA. GCA will then change the PI name in the financial system. Sponsor approval may be in the form of an award modification or amendment.

Human Subjects Research: Change of PI

When human subjects research is involved, the following actions must be promptly taken when (or just before) a PI is replaced or moves to another institution:

• Submit a modification to the IRB reviewing the study
• Change the responsible party at ClinicalTrials.gov, if the study is a registered clinical trial

Animal Subjects Research: Change of PI

When animal subjects research is involved, the following actions must be promptly taken when (or just before) a PI is replaced or moves to another institution:

• Submit an amendment to the IACUC protocol(s)
• Reach out to OAW with questions or for assistance transferring animals to another institution oawrss@uw.edu.

Key Personnel Changes

Similar to when there is a Change of PI, when there are Other Key Personnel changes, sponsor prior approval is often required. Review your notice of award and other sponsor guidelines before sending requests to OSP for review and submission to the sponsor.

Verify the Key Personnel have not been debarred or suspended.

• Submit a SAGE Modification Request (OSP/GCA), select Programmatic Change, add a note in the comments this is a request to change Key Personnel
• Attach a completed concurrence letter to the Modification Request
• Include an explanation of the change in MOD Comments field
• Attach a replacement Personnel Biographical Sketch
• Update any budgetary changes on the award budget in SAGE Budget as needed
  • Attach an exported excel version of the SAGE Budget or Create a budget snapshot in SAGE Budget and include a link to that snapshot in the comments field of the Modification Request.
  • For budget changes to an existing award line, include the UW Award Line Worktag(s) (GRXXXXXX)# along with the request for budgetary changes so GCA will know which Grant ID changes should be applied to.
  • Select Funding and Budgeting Change in addition to Programmatic Change
• Provide details on changes to the scope of work that result from personnel changes and also select the Programmatic MOD Type

Key Personnel Effort Changes - Includes PI

A significant reduction in effort (25% or more) for the PI or other key personnel usually requires prior sponsor approval. Reduction includes absence from the project for an extended period of time of 3 months or more.

Review your notice of award and other sponsor guidelines before sending Modification requests to OSP for review and submission to the sponsor.

Create a SAGE Modification Request (OSP/GCA) and include:

• Explanation of necessary change
• Any scope of work change as a result
• Update Awarded SAGE Budget Worksheet(s)
  • Attach an exported excel version of the SAGE Budget or Create a budget snapshot in SAGE Budget and include a link to that snapshot in the comments field of the Modification Request.
  • For budget changes to an existing award line, include the UW Award Line Worktag(s) (GRXXXXXX)# along with the request for budgetary changes so GCA will know which Grant ID changes should be applied to.
• Sponsor approval for named key personnel, if you already have it
• Updated Cost Share Addendum attached to MOD if cost shared effort involved and will change

Location Changes

Submit these Modification Requests to GCA only.

Note that a change in location mid-project (on- to off-campus) does not trigger an F&A rate change, by policy. See GIM 13.

Addition of Sponsor Property

If a sponsor will be issuing government property for use, or funding the development of property owned by the government, the PI/unit should consult with the Equipment Inventory Office (EIO). Most of the inventory reporting requirements are handled through EIO processes.

Work Scope Change

• Create a SAGE Modification Request (OSP/GCA), select Programmatic Change, include a note in the comments that is is a request for a Work Scope Change
• Attach a concurrence letter describing intended change in scope, scientific justification or other sponsor required information to make the request.
  • If the PI already has an award modification in hand, attach it to the Modification Request to OSP
• An updated SAGE Budget Worksheet is not needed unless the change leads to rebudgeting, in which case also select Funding & Budgeting, and
  • Attach an exported excel version of the SAGE Budget or Create a budget snapshot in SAGE Budget and include a link to that snapshot in the comments field of the Modification Request.
  • For budget changes to an existing award line, include the UW Award Line Worktag(s) (GRXXXXXX)# along with the request for budgetary changes so GCA will know which Grant ID changes should be applied to.
• The PI, Personnel & Organizations page of the original eGC1 should be updated, if necessary.

At the time sponsor approval is achieved, OSP will verify with the PI that intended compliance changes that require separate protocol or compliance office approval are in place. Steps a PI may need to take to initiate changes to protocol approvals:

• Human Subjects: Submit a modification to the IRB reviewing the study.
• Animal Use: Submit an amendment to the IACUC protocol(s). Reach out to OAW with questions or for assistance transferring animals to another institution oawrss@uw.edu.
• Changes that introduce new or changes to SFI: Disclose in FIDS to make updates.

Award Schedule Changes - Start Date Changes

When there are start date changes to an award and prior sponsor approval is required, create a Modification Request (OSP/GCA).

When start date changes do not require sponsor approval, create a Modification Request (GCA). GCA encourages including their optional GCA Modification Checklist along with your GCA only Award Modification requests.

Extension

A (no-cost) extension gives a Principal Investigator (PI) additional time on an awarded project without additional funding. It can be requested mid-project (temporary) or towards the end of the project.

Sponsors may have limitations on the timing and notification of an extension. Review the award and sponsor regulations.

All extensions for awarded projects (even those already approved by the sponsor) require compliance review and approval by OSP. Review the instructions for submitting an extension request.

• If your award has annual reporting requirements, you may need to request an advance instead of an extension
• If an award has not been made, and you want to extend a pre-existing Advance, review guidance from Grant & Contract Accounting on Advance Set Up & Extension

End of project extension requests should be submitted 45 business days before the award end date.

Create a SAGE Modification Request (OSP/GCA)

• Select Schedule Change, indicate Extension Request in the comments field
• Attach a copy of your completed Extension Request form
• If no sponsor system of submission is involved, or this is a second no-cost extension, also attach a concurrence letter requesting additional time and a scientific justification for the additional time (e.g. remaining funds to expend is not a justification)
• If a sponsor uses an electronic system for submission of the request, use that system to prepare and forward your request to OSP (AOR)
  • An example is eRA Commons (NIH) or Research.gov (NSF)
  • Review Some Sponsor Specific Extension Request/Notification Processes
• An updated SAGE Budget Worksheet is not needed
• The PI, Personnel, & Organizations page of the original eGC1 should be updated, if necessary
• Investigators should update their SFI disclosure if they have not renewed their SFI or if there is new or updated SFI to disclose

Some Sponsor Specific Extension Request/Notification Processes

In addition to using the Extension Request form and Creating a SAGE Modification Request, we must notify or request an extension from the sponsor. Sometimes this is done by OSP and sometimes by the PI.

In all cases, OSP compliance review & approval must be requested via a SAGE Modification Request (OSP/GCA).

Temporary Internal Extension

A temporary internal extension allows you to extend an award so you can continue posting expenses while awaiting formal extension processing.

• Create a Modification Request in SAGE (OSP/GCA), select Schedule Change, indicate temporary internal extension request in the comments field
• Attach a copy of your completed Extension Request form
• You must provide an alternative departmental non-sponsored project worktag on the extension form
• Note: Temporary internal extensions are no more than 6 months per request up to 12 months total

If the sponsor does not approve the extension, the department worktag will be used to cover those expenses.
GCA cannot invoice sponsors for expenses accrued past the current approved end date.

Automatic Carryover & Temporary Internal Extensions

If you are waiting for an award modification from the sponsor to be fully executed and the terms & conditions of the award indicate Automatic Carryover, you should request a Temporary Internal Extension. Please review guidance for Temporary Internal Extensions. Expenditures under the Temporary Internal Extension period will not be billed until the sponsor approved modification has been processed

Early Terminations, Relinquishments, and Award Transfers

Early Terminations

Early termination is shortening the life of the project prior to completion. Some reasons might include:

• Sponsor and/or Principal Investigator (PI) decide to end the project earlier than planned
• PI is leaving the University
• Programmatic or financial reasons to end a project earlier than planned
• Receipt of a competing renewal that overlaps a previous competing segment
• Early terminations may also involve a deobligation or revision to the award amount

Relinquishments and Award Transfers

Relinquishments and award transfers mean returning funds back to the sponsor and giving up the UW’s right to the funding. If another entity will be taking over the award, the sponsor re-issues the award as a new award to that entity. It is not a transfer directly from UW to the new entity.

Even if the end date is shortened, closeout requirements still apply per the terms and conditions of the award. Make sure to get all closeout documentation from the PI before they leave the UW.

How to Request an Early Termination or Relinquishment:

• Complete the relevant portions of the End of Award request form, attach to a SAGE Modification Request (OSP/GCA), and select End of Award Changes
• If there are active subawards, you will also need to request a subaward modification request in SAGE Subawards to terminate subawards.
• If the sponsor initiates an early termination and you received an amendment to your award, attach the amendment along with a completed End of Award request form to a SAGE Modification Request (OSP/GCA) and select End of Award changes.
• If animals are also being transferred with the transfer of an award: Contact OAW
• Review the following sections on NIH relinquishments for additional instructions.

NIH Relinquishments

• Indicate the estimated, unexpended balance of the award being returned to NIH on the NIH relinquishment request form. Estimates should be comprehensive and include all outstanding obligations. The amount indicated will be deobligated and returned to NIH.
• Contact GCA Help via Award Portal for more information or for help completing the form before submitting to the Office of Sponsored Programs (OSP).
• Attach completed NIH relinquishment form to a SAGE Modification Request (OSP/GCA).
• OSP will submit the request to NIH in eRA Commons.