Award Modifications

Administrative Modifications are changes to an existing award that do not affect the approved budget total or the approved performance period of the award and are updated in the Research Administration System (RAS). Typically, prior approval from the Sponsor is required before the Administrative Modification can occur.  

The Proposals and Grants team provides support for administrative modifications not requiring negotation to awards from all sponsor types except government and for-profit contracts. The Awards team provides support for administrative modifications requiring substantive negotation to awards from non-profit sponsors and incoming subawards/subcontracts. The Government Contracts team provides support for administrative modifications to federal, state, municipal or foreign government contracts. 

General Process

After the Principal Investigator, department sponsor request an administrative modification: 

If required, OSR completes a CACTAS correspondence record documenting prior approval requests sent to the sponsor. OSR ensures that compliance requirements (e.g. PI Status, COI, IRB/IACUC approvals, approval of all parties involved) are in place. 

Once approvals and compliance are completed, OSR creates an Admin Modification CACTAS record and submits it to Contracts and Grants Accounting (CGA). 

CGA completes the CACTAS record and updates the award in RAS. 

Award Modification Types

The following are examples of changes that do not require substantive negotation. 

Carryforward

Carry forward consists of unobligated funds remaining at the end of any budget period that, with the approval of the sponsor, may be carried forward to another budget period to cover allowable costs of that budget period (whether as an offset or additional authorization). When the sponsor is the NIH, carry-forward approval may be provided by either the GMO or UCSF’s expanded authority.

Change in Key Personnel

Key Personnel are those considered to be of primary importance to the successful conduct of a research project.

  1. For tNIH, key personnel are named in the Notice of Award (NoA). See the NIH definition of key personnel for additional information. Prior approval is required if the Key Personnel will:
    • Withdraw from the project.
    • Be absent for any continuous period of 3 months or more.
    • Reduce of the level of effort devoted to project by 25 percent or more from what was approved in the initial competing year award. 
      Selecting Yes in the RPPR constitutes a prior approval request to the agency and the issuance of a subsequent year of funding constitutes agency approval of the request.

  2. For other sponsors, OSR will review and determine if prior approval is required

     

Change in Status of Award PD/PI and/or Department

If the PD/PI of an award changes departments or steps down as PD/PI on the project, the sponsor must be notified prior to the effective date of the change and the following University requirements must be met:

  1. If the award PD/PI changes departments and takes the award with them (e.g. most research grants and individual instructional grants), the change can be handled internally unless sponsor approval is required per the terms of the award.
    • The change must be approved by the exiting PD/PI, Department Chair of the initial department and the Chair of the department the PI is moving to.
    • Concurrence is then provided by an Institutional Officer.
  2. If the award PD/PI leaves the department or the institution, but the award will stay with administering department (e.g.:  Institutional Training Grants), a request to change the PD/PI of the award must be approved by the sponsor prior to initiating an Administrative Modification of the award.
    • The prior approval request must be signed by the exiting PD/PI, the new PD/PI and the Department Chair.
    • The concurrence of an Institutional Officer is required prior to submission to the Sponsor.
  3. If the award PD/PI steps down from the PD/PI role and assigns a new PD/PI from a different department:
    • A prior approval request must be sent to the sponsor.
    • Both PIs and their respective Department Chairs must approve prior to receiving Institutional concurrence (all parties must be in agreement to the change and outcome of the change, such as change in the provider of the facilities and resources used by the project).
  4. If the PI is transferring to a different institution, please see Early Termination/Relinquish Award.
No Cost Extension (NCE)

Request for additional time (without additional funds), extending the last year or budget period of an existing award. Unless the sponsor has delegated UCSF the authority to extend an existing award, UCSF must seek permission from the sponsor. 

OSR has the authority to approve the 1st time NCE Award under expanded authorities in the eRA Commons.  All other awards typically require sponsor approval.

Change in Scope of Work (SOW)

The scope of work (SOW) may change from what was originally awarded by the sponsor. Changes in scope require prior approval from the sponsor.  Principal Investigators (PIs) are responsible for initiating amendments/changes to the project scope. 

Indicators of a potential change in scope include: 

  • Rebudgeting of 25% or more of Total Costs (TC) in a single budget period
  • Purchase of equipment exceeded $25,000
  • Change in status of Key Personnel (i.e., change in effort or departure)
  • Change in use of animals or involvement of human subjects
  • Shift in the research emphasis

OSR staff will ask the Principal Invesitgator to confirm any changes in scope. 

Re-budget

Re-budgeting is the re-appropriation of a portion of the approved budget from one budget category to another and does not involve the increase or decrease of the approved budget total. For example, removing technical staff because the service will be performed by an outside vendor will require moving personnel funds to other direct costs.

  1. For the NIH, a change of 25% or more in any budget category or a change from equipment to another category of the approved budget of a non-modular grant may require prior approval if the incurrence of costs is associated with or is considered to be a change in the scope. (e.g. The shifting of substantive programmatic work to a third party through a consortium agreement will result in the shifting of personnel, supplies and a portion of indirect costs to consortium/contractual costs.)
  2. For non-NIH sponsor, OSR will check grant guidelines to determine when prior approval is required for re-budgeting.
Place or Lift Restrictions

The sponsor may place a restriction on the spending of funds until compliance requirements are met. 

In the rebudgeting example, if a third party consortium agreement is to conduct human subjects research, and was not originally on the approved proposal and budget, the sponsor may approve the change in scope and rebudgeting of funds with a restriction on subcontract funds until compliance requirements are met. 

Early Termination

Early termination is the process required to end an award before the published expiration date.  

Approval of the administering department is first required.  An award can then be terminated early given prior written approval from the sponsoring agency.

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