Prior Approval System

In keeping with the greater flexibility allowed under OMB Circular A-110 (“Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education…”) and the major Federal agencies’ implementation of those requirements, Boston University has reviewed its policies and procedures with respect to institutional prior approval of certain actions related to Federal grants. Several actions for which University prior approval had formerly been required will no longer require such approval.

There are certain grant actions which will continue to require prior approval by the funding agencies and certain ones which will continue to require University prior approval; however, many grant actions will now require only that the Principal Investigator and/or the Department maintain a written explanation or justification for audit purposes. No additional University approval or rebudgeting will be necessary in these cases.

The table below summarizes Boston University’s prior approval policies.

  • For actions requiring Agency approval, please contact OSP.
  • For actions requiring institutional approval, please submit an IPAS form to OSP.
  • These provisions may be superseded by individual award terms and conditions.
  • To view the full agency regulations please click on the appropriate link below.
Sponsor PI Status Scope/Objectives No-Cost Extension Pre-Award Costs Equipment Domestic Travel/Foreign Travel Subcontracts Rebudgeting
AFOSR AFOSR prior approval is required for change of PI, absence of PI for 3 or more months or reduction of PI effort by 25% or more AFOSR prior approval is required for change in scope or objectives. AFOSR prior approval is required. Pre-award costs may be approved institutionally for costs incurred within 90 days preceding the effective date. No approval required. Equipment must be necessary for the research and not otherwise available.
*please see footnote		 No approval required. Travel must be necessary for the research and conducted in accordance with Federal
regulations and University
policy.
*please see footnote		 AFOSR/ AFRL prior approval required for subcontracts not included in the approved budget.
ARO ARO prior approval is required for changeof PI, absence of PI for 3 months or more or reduction of PI effort by 25% or more. ARO prior approval is required for change in scope or objectives. ARO prior approval is required. Pre-award costs may be approved institutionally for costs incurred within 90 days preceding the effective date. ARO prior approval required for all equipment costing $5,000 or more and not included in the approved budget.
*please see footnote		 ARO prior approval required for foreign travel not included in the approved budget.
*please see footnote		 ARO prior approval required for subcontracts not included in the approved budget.
DOE DOE prior approval is required for changeof PI, absence of PI for 3 months or more or reduction of PI effort by 25% or more. DOE prior approval is required for change in scope or objectives. One time extension for up to 12 months may be approved institutionally. DOE must be notified with supporting reasons no later than 10 days prior to expiration date. Pre-award costs may be approved institutionally for costs incurred within 90 days preceding the effective date. No approval required. Equipment must be necessary for the research and not otherwise available.
*please see footnote		 No approval required. Travel must be necessary for the research and conducted in accordance with Federal regulations and University policy.
*please see footnote		 DOE prior approval required for subcontracts not included in the approved budget.
NASA NASA prior approval is required for changeof PI, absence of PI for 3 months or more or reduction of PI effort by 25% or more. NASA prior approval is required for change in scope or objectives. One time extension for up to 12 months may be approved institutionally. NASA must be notified with supporting reasons no later than 10 days prior to expiration date. Pre-award costs may be approved institutionally for costs incurred within 90 days preceding the effective date.
 NASA prior approval required for general and special purpose equipment costing $5,000 or more and not included in the approved budget.
*please see footnote		 No approval required. Travel must be necessary for the research and conducted in accordance with Federal regulations and University policy.
*please see footnote		 NASA prior approval is required for all subcontracts greater than $100,000 not included in the approved budget. Subcontracts of $100,000 or less not included in the approved budget may be approved institutionally.
NIH
more at: Exhibit 7		 NIH prior approval is required for changeof PI, absence of PI for 3 months or more or reduction of PI effort by 25% or more. NIH prior approval is required for change in scope or objectives. One time extension for up to 12 months may be approved institutionally. NIH must be notified with supporting reasons no later than 10 days prior to expiration date. Pre-award costs may be approved institutionally for costs incurred within 90 days preceding the effective date. No approval required. Equipment must be necessary for the research and not otherwise available.
*please see footnote		 No approval required. Travel must be necessary for the research and conducted in accordance with Federal regulations and University policy.
*please see footnote		 NIH prior approval is required for subcontracts not included in the approved budget only if transfer would be to a foreign component or result in a change in scope. Prior approval required when expenditures in a direct cost category increase/ decrease by more than 25% of the total award. (N/A to modular grants.)
NSF NSF prior approval is required for changeof PI, absence of PI for 3 months or more or reduction of PI effort by 25% or more. NSF prior approval is required for change in scope or objectives. One time extension for up to 12 months may be approved institutionally. NSF must be notified with supporting reasons no later than 10 days prior to expiration date. Pre-award costs may be approved institutionally for costs incurred within 90 days preceding the effective date. N o approval required. Equipment must be necessary for the research and not otherwise available.
*please see footnote		 No approval required. Travel must be necessary for the research and conducted in accordance with Federal regulations and University policy.
*please see footnote		 NSF prior approval required for subcontracts not included in the approved budget. NSF prior approval is required for reallocation of funds budgeted for participant or trainee support costs.
ONR ONR Prior approval is required for change of PI, absence of PI for 3 months or more. ONR prior approval is required for change in scope or objectives. ONR prior approval is required. Pre-award costs may be approved institutionally for costs incurred within 90 days preceding the effective date. No approval required. Equipment must be necessary for the research and not otherwise available.
*please see footnote		 No approval required. Travel must be necessary for the research and conducted in accordance with Federal regulations and University policy.
*please see footnote		 ONR prior approval required for subcontracts not included in the approved budget.

Footnotes:

* Equipment: The PI/Department must ensure that all equipment purchases are: (a) primarily or exclusively used in the actual conduct of the research or activity supported by the grant; (b) not otherwise reasonably available and accesible; (c) of the type normally charged as a direct cost to sponsored agreements; and (d) acquired in accordance with organizational practice.
* Travel: All foreign travel must be performed by, or under a code-sharing arrangement with, a U.S. flag air carrier to the maximum extent possible. This requirement must not be influenced by factors of cost, convenience, or personal travel preference. The Office of Grant & Contract Accounting should be contacted prior to the purchase of airline tickets for questions regarding documentation required to support charges related tot he use of a non-U.S. flag air carrier.