Department of Education

DE
NON-DISCRETIONARY
FUNDING
DISCRETIONARY
FUNDING
ACTION ITEM:
APPROVAL BY
APPROVAL BY
Change in scope or objective of project or program
Sponsor
Sponsor
Changes in named personnel
Sponsor
Sponsor
Restrictions on Notice of Grant Award
Sponsor
Sponsor
Change in Grantee Institution
Sponsor
Sponsor
Transferring program work
Sponsor
Sponsor
Need for additional funding
Sponsor
Sponsor
Pre-award costs more than 90 days
Sponsor
Sponsor
Second request for extension of time
Sponsor
Sponsor
Alterations & Renovations
Sponsor
Sponsor
Transferring amounts from trainee costs
Sponsor
Sponsor
Transfer of funds between construction and nonconstruction
grants
Sponsor
Sponsor
Equipment (Capitalized), not in budget > $5000
Sponsor
Sponsor
Rebudgeting F&A costs to absorb increases iin direct costs or
vice versa
Sponsor
Sponsor
Program Income
Sponsor
Sponsor
Foreign travel
Purdue
Purdue
Equipment (Capitalized), not in budget < $5000
Sponsor
Purdue
Carry forward of unobligated funds
Sponsor
Automatic
Extension of time w/o additional funds (one time up to 12 months)
Sponsor
Purdue
Pre-award costs 90 days or less
Sponsor
Automatic
Rebudgeting between direct line items
Sponsor
Purdue

Prior Approval Authorities For DE Grants

I. IMPLEMENTING GUIDELINES:
A. Institutional Approval
Certain actions have been delegated to the institution for prior approval. Should a need for prior approval arise and if it meets the criteria identified in Section III, the principal investigator should prepare a written request to the institutional official authorized to grant prior approval which incorporates the following:
* the exact nature of expenditure

* the need for the requested activity

* the budget categories which would be altered

* any significant effect on the general scientific direction of the project

* signatures of both the department head and business office

The Director, Associate Directors, and Assistant Directors of Sponsored Programs Services have been designated as the institutional officials to review and approve rebudgeting requests. They will obtain fiscal approval from the appropriate SPS Project Administrator before making a final decision to approve the
request. The rebudgeting must neither impair the investigator's ability to complete the project as approved nor increase the total cost to the grant. The authorized designee will review the request for scientific or program propriety in relation to the objectives of the specific project supported by the grant to which the charges will be made. Final approval or disapproval will be indicated in writing.

Each documented request (both approved and disapproved) will be kept in the Sponsored Programs Services Office for audit purposes.

In cases where Sponsored Programs staff have difficulty in determining the appropriateness of the prior approval, SPS staff will consult with the academic department to determine if additional information or justification is required.

B. DE Approval
There are certain activities that require approval from the DE awarding office before that action may be taken. These requirements are specified in Section II and IV of this document. The principal investigator should address the request to the DE Programs Officer. The request must be signed by the PI, department head and business office. The request must then route through the Sponsored Programs Services Office to be countersigned.
II. ACTIONS WHICH ALWAYS REQUIRE DE PRIOR APPROVAL
The following list is a summary of the current items which require DE prior written authorization before execution. This list may not be all inclusive since it is possible that the specific award has identified restrictions, or that our cognizant audit agency has placed additional requirements for prior approvals on the institution.
1. Change of Scope or Objective of the Grant Supported activities.

2. Changes in Named Personnel.

A. DE prior approval is necessary for replacement or significant change in responsibilities of the approved principal investigator or project director on research grants. A significant change occurs when there is a 25% eduction in the level of effort.

B. DE prior approval is needed if the Notice of Grant Award for a non-research grant specifically states a prior approval requirement is imposed for any replacement or significant change in responsibilities of persons expressively identified on the award as key project staff.

C. On all DE grants, the continuation of the project during any continuous period of more than 3 months without active direction of an approved project director or principal
investigator.

3. Restrictions on Notice of Grant Award. Prior approval is necessary to undertake any activities disapproved or restricted as a condition of the award.


4. Change of Grantee Institution

5. Transferring Programmatic Work (subcontract). DE approval is required to enter into any subcontract arrangement that was not specified in the proposal. This does not apply to procurement
activities.

6. Need for Additional Funds. DE prior approval is required when there is a need for the award of additional federal funds.

7. Preaward Cost Incurred More than 90 Days Prior to the Effective Date of Any New or Competing Continuation Award.

8. Second Extensions of Budget Periods -beyond an extension that was granted by the University or DE.

9. Alterations and Renovations-Any costs not specified in the proposal require DE approval.

10. Transferring Amounts from Trainee Costs. DE prior approval is necessary for the transfer of amounts previously awarded for trainee costs. (stipends, tuition and fees) to other categories of expense.

11. Transfer of Funds Between Construction and Nonconstruction.

12. Scientific Equipment (Capitilized), Not in Budget > $5,000 Acquisition of special purpose equipment, costing in excess of $5,000 and not included in the approved proposal budget, requires the prior approval of the administrative grant officer (unless the item is merely a different model of an item in the approved proposal budget).

13. Rebudgeting F&A costs to absorb increases in direct costs or vice versa.

14. Program Income

III. ACTIONS WHICH REQUIRE PURDUE APPROVAL
The following identifies the situations in which authority to grant a rebudget may have been granted to the institution. In all cases, the rebudget being requested must contribute to the scope and purpose of the project. Any requests which deal with the subject matter below should be submitted for approval as described in Section I.

1. Foreign Travel. Approval is required for all trips not specifically identified in the proposal. U.S. flag carriers must be used in accordance with government policy. This requirement cannot be influenced by cost, convenience, or personal travel preference.

2. Scientific Equipment (Capitilized), Not in Budget < $5,000

Any scientific equipment with an acquistion cost > $1,000 but less than $5,000 can be approved by the University.

IV. ACTIONS WHICH REQUIRE EITHER DE OR PURDUE APROVAL DEPENDING ON DISCRETIONARY OR NON DISCRETIONARY STATUS
1. Carryforward of unobligated funds
a) Discretionary authority - University is authorized to automatically carryforward unobligated funds remaining at the end of each budget period. -

b) Non Discretionary authority - Requires DE approval.

2. No cost extensions

a) Discretionary authority - The University may approve the extension of the final budget period of a research project one time for a period up to 1 year beyond the original expiration date. Request for internal approval must be made 30 days prior to the grants expiration date. Purdue must notify DE of any extensions 10 days prior to the expiration date.

An extension can be made only when no additional funds are needed and any one of the following apply: (The fact that funds remain at the end of a project period is not in itself sufficient justification for an extension.)

* Additional time beyond the established expiration date is required to assure adequate completion of the originally approved project.

* The extension is necessary to permit an orderly phaseout of a project that will not receive continued support.

3. Preaward Costs

a) Discretionary authority - A grantee may, at its own risk, incur obligations and expenditures to cover costs prior to the effective date of an award provided the following criteria are met: the costs concerned are considered necessary to the conduct of the project, the costs are allowable under the potential award, and when required for specific expenditures or activities, DE prior approval was obtained. No formal University approval is required (no prior approval letter). In circumstances where a correcting document is prepared, an appropriate explanation will state that the transfer is being executed under the preaward authority of the university. (Please refer to the correcting document training packet for explanations and examples)
b) Non Discretionary authority - Requires DE approval.

4. Rebudgeting between direct line items

a) Discretionary authority - Grantee may transfer funds among direct line items
b) Non Discretionary authority - Requires DE approval

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