In general, sponsors must approve subcontracts not identified in the original budget. Appropriate paperwork from the proposed subcontractor must be included: an LOI signed by the subcontractor’s authorized institutional representative, a statement of work, and a budget and budget justification. If the subaward was not included in the original proposal, an Add-on subcontractor request must be submitted to SPA through PEER.
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
not originally identified in the budget. Such requests are submitted via PEER and may be approved by SPA 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.
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 Vanderbilt. See below for examples.
Refer to the sponsor’s regulations and award documents and contact your SPA representative with specific questions regarding such changes. Requests to sponsors must be authorized by SPA 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)
- For federal awards, the OMB Unified Guidance 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.
Vanderbilt utilizes PEER to review changes that may be institutionally authorized. See PEER Manual for directions on how to submit a request through PEER.
Transfer of Grant to or from Vanderbilt
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 Vanderbilt is the receiving institution then the Department should initiate the Coeus proposal for a "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 Vanderbilt from other institutions will have a lower Facilities and Administrative (F&A) rate than Vanderbilt's negotiated federal rate. In some circumstances Vanderbilt 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.