Examples
Worked examples
- Is an instance
A PI wants to change the specific aims of an NIH-funded project mid-award because early results point to a more promising research direction than the one described in the approved application. This is a change in the scope or objective of the project under 2 CFR 200.308(f), so the recipient's Signing Official must submit a prior-approval request to the NIH Institute/Center before the PI proceeds, not after — proceeding first and reporting the change in the next progress report does not satisfy the requirement.
- Is an instance
A recipient institution has already used its one automatic, expanded-authority no-cost extension (up to 12 months, exercised through the awarding agency's system before the project period ends) and now needs a second extension because the project still isn't finished. A second no-cost extension is not covered by expanded authority — it is a 200.308(f) prior-approval event, requiring a formal request with justification to the awarding agency before the original end date passes. See the CASRAI no-cost extension entries for the full request lifecycle.
Counter-examples
Looks similar, but isn't
- Not an instance
A PI moves funds between two existing line items within the approved budget in a way that does not touch a category 2 CFR 200.407 or 200.308 names — for example, shifting a modest amount from one already-budgeted supply line to another, with no change in scope, no new subaward, no key-personnel change, and no cost-sharing effect. Because this does not match any of the enumerated triggers, it is a routine budget-management decision the recipient can make on its own authority; it is not a prior-approval matter simply because it involves moving money.
- Not an instance
A recipient exercises its first, one-time no-cost extension under an agency's standard expanded authority — available automatically before the project end date, requiring only notification through the agency's system rather than a justified request. Because expanded authority exists precisely to remove this specific, low-risk action from the prior-approval requirement, it is the named exception, not an instance, of prior approval.
Editorial commentary
Prior approval functions as a risk-allocation mechanism inside the Uniform Guidance: it moves the burden of judgment about a defined set of higher-risk actions from the recipient institution to the federal awarding agency, before money is spent or a decision is executed, rather than leaving the agency to evaluate the decision retroactively during monitoring or audit. This matters operationally in two directions. For a recipient, correctly identifying that an action is a 2 CFR 200.407 or 200.308(f) trigger — and routing the request through the institution’s Signing Official rather than having a PI act unilaterally — is what keeps an otherwise defensible decision from becoming an audit finding or a disallowed cost. For an agency, the enumerated, closed list is what keeps prior approval from becoming an open-ended veto over routine project management: 200.407 states plainly that the absence of prior approval does not itself make a cost unreasonable or unallocable unless prior approval is specifically required for that item.
In practice, most institutions route prior-approval requests through the same office that manages no-cost extensions and other post-award actions, since the underlying regulatory logic and the internal sign-off chain (Signing Official, not PI) are the same. Because prior approval is one of the named risk factors federal awarding agencies weigh when assessing an applicant or recipient’s overall risk profile under 2 CFR 200.206, a pattern of prior-approval requests — or of after-the-fact discoveries that a recipient acted without required approval — can itself feed into an agency’s risk indicators and thresholds assessment and lead to more intensive monitoring on future awards. Recipients should also check their award’s specific terms and conditions and their funding agency’s own policy statement (for example, the NIH Grants Policy Statement), since agencies can and do specify additional prior-approval triggers, dollar thresholds for equipment or foreign travel, and request procedures beyond the Uniform Guidance floor.
Machine-readable encodings
Use in your systems
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"description": "<p><strong>Prior approval</strong> (sometimes written “prior written approval”) is the requirement, under <a href='https://www.law.cornell.edu/cfr/text/2/200.407'>2 CFR 200.407</a> of the OMB <a href='/guides/uniform-guidance-2-cfr-200'>Uniform Guidance</a>, that a federal grant recipient obtain the federal awarding agency’s written sign-off <em>before</em> taking a specified action, rather than proceeding and defending the decision after the fact. Something is genuinely a “prior approval” matter — as opposed to routine project management the recipient can handle on its own authority — only if it falls into one of the categories the regulation or the recipient’s own award terms specifically names. Section 200.407 lists sixteen such categories, including cost sharing (200.306), program income (200.307), revision of budget and program plans (200.308), fixed-amount subawards (200.333), compensation for personal services and fringe benefits (200.430–200.431), equipment and capital expenditures (200.439), exchange-rate losses (200.440), fines and penalties (200.441), fundraising costs (200.442), goods or services for personal use (200.445), insurance and indemnification (200.447), organization costs (200.455), pre-award costs (200.458), rearrangement and reconversion costs (200.462), and travel costs (200.475). The regulation is explicit that the <em>absence</em> of prior approval does not, by itself, make a cost unreasonable or unallocable unless prior approval is specifically required for that item — the requirement only bites where it is named.</p><p>The most frequently triggered prior-approval events sit inside <a href='https://www.law.cornell.edu/cfr/text/2/200.308'>2 CFR 200.308</a>, “Revision of budget and program plans,” which requires a recipient to ask before: changing the scope or objective of the project (even without any budget change), changing key personnel identified by name or position in the award, a PD/PI disengaging from the project for more than three months or reducing time and effort on it by 25 percent or more, redirecting participant support costs to other budget categories, adding a subaward not proposed in the original application, changing the total approved cost-sharing amount, needing additional federal funds to complete the project, moving funds between construction and non-construction categories, or extending the project period beyond what the recipient’s own expanded/automatic authority already covers. Because 200.308’s list is itself an enumerated set — not a general “ask if unsure” standard — a change that doesn’t match one of its named triggers, or one of 200.407’s other named cost categories, does not require prior approval merely because it feels significant to the PI.</p>",
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