To:         Principal Investigators and Grant Administrators

From:     Bruce C. Fehn
              Andrew B. Rudczynski

Subject:  Institutional Prior Approval System (IPAS) for Rebudgeting Under the Expanded Authorities

As a result of the Federal Demonstration project, the National Science Foundation (NSF) and Public Health Service (PHS) have relinquished most Agency authority for post-award prior approvals. These agencies have been joined by many other Federal agencies in an attempt to reduce paperwork involved with the management of Federal grants. We have reviewed the institutional prior approval requirements as they pertain to the major Federal agencies and are waiving the institutional prior approvals for rebudgeting of funds where the terms of the grant no longer requires them. This applies only to grants under the expanded authorities. In addition, Department Chairs or Center Directors will now become the Responsible Official for approving the IPAS form for Principal Investigators. A Principal Investigator who is also a Department Chair or Center Director should seek the approval of the next highest academic authority. We believe these changes will improve the post-award administration process and are in the spirit of the recommendations of the Committees on Administrative Systems Efficiency and Routine Requests for University Action (Red Tape).

Subject to the terms of the individual grant, institutional prior approval is no longer required for the following:

The waiver of institutional prior approvals does not apply to changes in the scope of work, changes in key personnel, or other approvals and terms specifically required by the grant or sponsoring agency. Principal Investigators are responsible for assuring that expenditures of grant funds are necessary to achieve program objectives supported by the award and that they represent effective utilization of resources.

Institutional prior approval is still required for requests of preaward costs and no cost extensions on all awards under the expanded authorities, The attached IPAS form is to be used for these requests click here

Prior Approval Requirements for Grants Under the Expanded Authorities

                                                                                                                              PRIOR
                                                                                                                              AGENCY
                                                                                                                              APPROVAL        IPAS
ACTIVITY                                            AGENCY                                     NOTES      REQUIRED     REQUIRED

Domestic Travel Re-budget         AGENCY AFOSR, ARMY                           A                  Y

Foreign Travel Re-budget            AFOSR, ARMY, NAVY, NASA                     B                  Y

Equipment Re-budget                AFOSR, ARMY, NASA                                C                  Y

Pre-award Costs                       AFOSR, , ARMY, NAVY, NASA                    D                                      Y
                                               NSF, PHS, DOE, USDA(CSRS)

No Cost Extension                    AFOSR, NAVY                                            E                  Y
                                               ARMY, NASA                                                                                      Y
                                               NSF, PHS, DOE, USDA(CSRS)                                                            Y

Change in:                               AFOSR, ARMY, NAVY, NASA                                          Y
Principal Investigator                 NSF, PHS, DOE, USDA(CSRS)                                        Y
Key Personnel
Sub-contracting

Notes on Prior Approval Requirements For Grants Under the Expanded Authorities

Note A - Domestic Travel

Agency requires notification before incurring domestic travel which exceeds the travel 'budget by $500 or 25%, whichever is greater.

Note B - Foreign Travel

Agency limits foreign travel to the amount initially approved in the budget and only to destinations specifically indicated. Any foreign travel which may exceed the budgeted amount or change the destination must have prior agency approval. This approval must be in writing before the trip is undertaken. Foreign travel to communist areas, foreign travel involving studies of foreign countries, per se, or foreign travel requiring special permits or licenses still requires prior approval by the Grants Officer, unless the travel has been described in an accepted proposal.

Note C - Equipment

AFOSR requires that the grantee provide notification to the Contracting Officer before purchasing any general purpose equipment or any permanent research equipment that costs $5,000, or more, unless the grant or cooperative agreement specifically identifies the equipment in the approved budget.

ARMY requires written prior approval on all general purpose equipment or specific purpose equipment costing $1,000 or more.

NASA requires written prior approval on all general purpose equipment or specific purpose equipment costing $5,000 or more.

Note D - Preaward Costs

Preaward costs may be requested, at the grantee's risk, up to 90 days before the start date of the grant.

Note E - No Cost Extension

This may be reqested for up to one year for all agencies, except for NSF which may not exceed six months. The no cost extension must be requested 30 days before the original termination of the grant.

revised 7/29/99