Lifting Funding Restrictions
Change of PI
Key Personnel Changes
Reduction in Effort of PI or Key Personnel
Early Terminations and Relinquishments
Sponsors may require prior approval before making certain changes to an award. Federal sponsors who grant expanded authorities may allow some changes without getting prior sponsor approval.
Examples of changes that may require prior sponsor approval include: extension of end date (aka no-cost extension or budget extension), a change of PI, lift funding restrictions, carry forward/carryover, programmatic changes, early termination or relinquishment, foreign national participation on specific Dept. of Energy Awards.
Review your award, sponsor guidance and additional instructions below based on the type of award change being requested.
Questions about award requirements?
Contact your department, school or unit Office of Sponsored Programs (OSP) reviewer.
Appendix A: Prior Approval Matrix
A budget extension gives a Principal Investigator (PI) additional time on a project budget number without additional funding. It can be requested mid-project or towards the end of the project.
Sponsors may have limitations on the timing and notification of a budget extension. Review the award and sponsor regulations.
All extensions for awarded projects (even those already approved by sponsor) require compliance review and approval by OSP. Review the instructions for submitting a budget extension request.
Funding changes on an award can occur for various reasons, either to increase or decrease the amount of an amount.
Sponsors typically issue a deobligation to reduce award amounts for the following situations:
Award will end early (e.g. early termination)
- Budget period (aka mid project deobligation on incrementally awarded project)
- Project period (aka deobligation during or after the project closeout) UW did not spend & draw down / invoice for the full award amount
What to do:
Forward the deobligation or revised award notification indicating reduced award amount to email@example.com and include:
- eGC1# in subject line
- PI confirmation accepting award amount reduction
- UW Budget number impacted
- Revised budget reflecting reduced award (if not provided as part of the award modification).
- GCA needs to know line items being impacted by reduction to complete process.
If an active subaward is affected, submit a subaward modification request.
There may be opportunities to add funding during the project, due to an expansion of the scope of work or the addition of new, related work. When you apply for supplemental funding, complete an eGC1 for the amount of the new funding.
Sometimes the approved 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.
Note: NIH accepts email concurrences and NSF notifications can be done in Fastlane.
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 includes the restrictive language from the sponsor in a comment on the Funding Action (FA) to the PI, Department and Grant and Contract Accounting (GCA).
When GCA receives the FA to set up the UW budget they will either place an encumbrance on the restricted funds or place the restricted funds in a sub-budget.
Sample Funding Restrictions:
- Human subjects research cannot happen until a copy of the IRB approval is provided to the sponsor
- Research involving animal use cannot happen until a copy of the IACUC approval is provided to the sponsor
- Sponsor requires additional documentation before they will issue a revised award to lift the funding restriction
- Funds can only be used for specific named personnel in the award.
- Funds are designated for a particular purpose (e.g. travel) and cannot be rebudgeted for something else without prior approval.
- Renovations must have prior sponsor approval on the designs before funds can be used
Prior sponsor approval required to lift funding restrictions?
Review your award and comments on your FA to determine if prior approval from the sponsor is required to lift funding restrictions.
Submit prior approval requests to OSP via firstname.lastname@example.org and include:
- Sponsor award # and eGC1 #
- Description of the request
- Explanation of how requirements have been met to release the restriction
- Supporting documentation that reflects requirement has been met (e.g. protocol approval)
After sponsor prior approval is obtained, OSP will send a Post-Award Change (PAC) to GCA. GCA will remove the encumbrance from the restricted funds or place the restricted amount from the sub-budget into the parent budget.
Prior Sponsor Approval NOT Required to Release Funding Restrictions?
The PI must communicate with GCA when conditions have been met that allow expenditure of those funds.
You may need to request a modification or changes to an outgoing subaward such as extending the end date, adding funding, changing milestones, etc.
Review guidance for requesting changes to your subaward.
Don’t forget you must also submit changes in the procurement system (Ariba) after you receive notification of a signed subaward modification for changes to:
- Funding (Ariba needs to reflect cumulative total for entire BPO, reflecting the amount available for invoicing)
- Period of performance
Programmatic changes that require prior sponsor approval typically include changes to the scope of work, addition or removal of key personnel, change in the use of human subjects or vertebrate animals.
Significant changes to human subjects or vertebrate animal protocols may also require institutional review and approval.
- Human Subjects Guidance for Modifying the study activities
- Office of Animal Welfare: Contact OAW to submit a significant change request.
Review your award and the sponsor requirements to ensure compliance with any programmatic changes.
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. If the change of PI is part of a larger project change that requires a new eGC1, please follow that process.
When only the PI is changing, a new eGC1 is not required. Have more questions? Review the Change of PI FAQs.
Change in PI Steps – Campus Units
- Verify the PI has not been debarred or suspended
- Complete the Change of PI Request
- Update SAGE/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. See Key Personnel Changes
- If the new PI was not already listed on the eGC1 and has not completed their SFI Disclosures, Send Disclosure Notifications
- Note: When the eGC1 has a sponsor withFCOI Training Required, after the Personnel updates happen the eGC1 may revert to displaying “PHS FCOI training required” for all Investigator personnel. This does not mean those who have already taken care of it need to do this again
- Navigate away from the PI, Personnel, & Organizations page and then back again to reset the training expiration dates to their current status
- If the eGC1 has a Non-FCOI Training Required sponsor, there is no impact and the system will continue to display “PHS FCOI training not required” for all Investigators
- Gather Supporting Documentation reflecting the new PI’s suitability for the role (such as their Biosketch and Other Support) as required by the sponsor.
- If Sponsor approval is still required: Draft a request for the change in PI to the sponsor on the new PI’s campus unit letterhead, signed by the new PI and the former PI or the Chair/Unit Lead (if former PI is unavailable) for OSP concurrence. This should include:
- Explanation of the necessary change
- Any budgetary or scope of work changes as a result
- Follow instructions to Email OSP for a Change of PI
Email OSP for Change of PI
Subject line of email: Change PI, eGC1 #, Old PI last name, New PI last name
- Completed & signed Change of PI Request form
- Proof of Sponsor’s authorized representative approval or If sponsor approval is outstanding, 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
After OSP receives the authorized sponsor representative’s approval of the change, OSP will send a Post Award Change (PAC) via SAGE 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 (email@example.com).
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.
- eGC1# in subject line
- Explanation of the change
- Replacement Personnel Biographical Sketch
- Any budgetary or scope of work change as a result
- Department chair concurrence
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 requests to OSP for review and submission to the sponsor.
Submit a request to OSP via firstname.lastname@example.org and include:
- eGC1# in subject line
- Explanation of necessary change
- Any budgetary or scope of work change as a result
Carryover (aka Carry Forward) is when the balance of unused funds at the end of a Budget Period is transferred (or carried forward) into 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.
- Submit a concurrence letter to OSP along with the following information:
- Amount of funds to be carried forward
- Explanation of unobligated balance (why did the budget not match expenditures?)
- Detailed budget of carryover amount (how are these funds going to be spent?)
- Scientific justification (how will this carryover impact/benefit the award?)
GIM 2: Acceptance of Sponsored Program Awards and Fiscal Compliance on Sponsored Program Accounts (Budget Numbers)
Early termination shortens the life of the project prior to completion. Relinquishments and award transfers mean returning funds back to the sponsor and giving up the UW’s right to the funding. Review guidance for early terminations and relinquishments.
Forms, Tools, and Resources
- Post Award Fiscal Compliance (PAFC)
- Concurrence Letter Sample
- Human Subjects Division (HSD)
- Budget Extension Request Tool
- GCA: Rebudgeting Funds on a Grant or Contract
- PAFC: Prior Approvals
- End of Award Request Form
- Procurement Services: Changing or Closing a Blanket Purchase Order
- Office of Sponsored Programs
- End of Award / Budget Review Checklist
- Request a Change of PI
Frequently Asked Questions
- Change of PI FAQs
- How do I find the status of my Post Award…
- How do I know if an NIH award is SNAP…
- How does the no-cost extension (budget extension) process work?
- I want to submit a request to my sponsor to…
- What is a no-cost extension?
- What is a temporary budget extension?
- When do I need to use an eGC1?
- Who, What, Why – Searching SAM.gov