Definition · Plain-language
Prior approval
Prior approval is the written authorisation a recipient must obtain from the sponsor before making specified changes or incurring specified costs on an award.
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What needs prior approval
Uniform Guidance at 2 CFR 200.308 lists the post-award changes that require the awarding agency’s written approval in advance. These commonly include a change in the project’s scope or objective, a change in the approved principal investigator or other key personnel, the absence of the PI for an extended period, the need for additional federal funds, and certain budget revisions or transfers between cost categories. Award terms and agency policy can add further triggers, so the award document is read alongside the regulation.
Why “before” is the whole point
The defining feature of prior approval is timing: the approval must be obtained before the change is made or the cost is incurred. Retroactive requests defeat the purpose, which is to let the sponsor agree to a material change while it can still influence the work. Costs incurred in anticipation of an approval that is never granted, or that should have been sought and was not, are generally unallowable. This is why research offices route potential changes through their sponsored-programmes office early.
Expanded authorities
To reduce administrative burden, agencies may waive certain prior-approval requirements under “expanded authorities”, delegating some decisions — such as carrying unobligated balances forward or making limited rebudgeting — to the recipient. Where expanded authorities apply, the recipient may act without asking, but must still document the decision and stay within the award terms. The scope of any waiver is set by the agency, so recipients confirm which authorities apply to each award rather than assume.
Key facts
At a glance
- Definition: sponsor’s written approval needed before an action or cost
- Authority: Uniform Guidance, 2 CFR 200.308
- Examples: change in scope, change of PI, additional funds, rebudgeting
- Timing: must be obtained in advance, not retroactively
- Consequence: acting without it can make costs unallowable
- Waivers: some requirements waived under “expanded authorities”
Common misconceptions
What people often get wrong
Often heard: Prior approval can be requested after you make the change.
Actually: Prior approval is, by definition, obtained in advance. Acting first and asking later can make the resulting costs unallowable and create an audit finding.
Often heard: Only spending more money needs prior approval.
Actually: Many non-budget actions need it too — a change in scope, a change of principal investigator, or an extended absence of the PI, among others listed in 2 CFR 200.308.
Often heard: Prior-approval rules are identical across every award.
Actually: Expanded authorities and agency-specific terms vary which actions require approval, so the award document and agency policy must be checked for each award.
Going deeper
