Prior Approval System

Overview of Federal Regulations
OMB Circular A-110, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations governs the administration of all federal grants, including changes to grant-funded projects. Recipients are required to report deviations and request prior approvals for budget and program plan revisions, in accordance with Section 25 of OMB Circular A-110. Prior approval means written approval by an authorized official evidencing prior consent.

Before making any project changes, the Principal Investigator/ Project Director must consult with the Director of Corporate, Foundation, and Government Relations. Internal approvals will be sought from the Controller and/or the Provost. All approvals must be documented to provide assurances to the appropriate federal agency.

Prior Approval
For non-construction awards, prior approval from Federal awarding agencies is needed for one or more of the following program or budget related reasons:

1. Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval).
2. Change in key project personnel specified in the application or award document.
3. The absence for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.
4. The need for additional federal funding.
5. The transfer of amounts budgeted for indirect costs to absorb increases in direct costs, or vice versa, if approval is required by the federal awarding agency.
6. The transfer of funds allotted for training allowances (direct payment to trainees) to other categories of expense.
7. The sub-award, transfer, or contracting out of any work under an award. This provision does not apply to the purchase of supplies, material, equipment or general support services.
Once reviewed and approved by the Provost and Controller, the request will be submitted to the funding agency by the Office of Corporate, Foundation, and Government Relations.

Institutional Prior Approval:
The OMB Circular and federal agencies delegate some authority to institutions to approve certain administrative actions. Hartwick College has instituted an Organizational Prior Approval System to ensure that adequate reviews and approvals are in place for decisions that affect the administration of grant-funded projects.

Administrative changes include:
• pre-award spending;
• no-cost time extensions;
• changing budget lines within the categorical budget;

The Principal Investigator/Project Director is authorized to make charges to grants provided that they agree with the approved budget. Changes to budgets are permitted if they:
• are allowable under OMB Circular 21 Cost Principles for Educational Institutions;
• are consistent with the terms and conditions of the award and with sponsor and Hartwick College policies;
• do not constitute a change in project scope;
• are reasonable, necessary, and allocatable to the project.

Before incurring any charges that deviate from the awarded budget, the PI/PD must submit a Prior Approval form to the Director of Corporate, Foundation, and Government Relations, who will review it with the Controller and Provost, and obtain the necessary signatures.

The signed OPAS form is retained in the grant file for three years following submission of the final financial report.