Prior sponsor approval is required for a change in objectives, scope, PI or project effort on some grants and contracts, especially federal grants or contracts.
Principal investigators must obtain sponsor approval before changing the objective or scope of any grant or contract. Examples, though not all inclusive, are as follows:
Sponsors often base decisions to award funds on the expertise of the PI. A change in PI is an important consideration in the sponsor’s decision to continue funding the research.
As soon as the principal investigator determines a project's performance will require additional time, with or without the need for additional funding, a written request cosigned by the PI and the appropriate University authorizing official must be submitted to the sponsor. Extensions that require additional funding must be processed through the Office for Sponsored Programs (OSP).
No-cost time extensions must be processed though Grants and Contracts Administration. Some federal projects allow a one-time, twelve-month, grantee-authorized extension in which the appropriate Grants and Contracts Administration manager notifies the sponsor that Clemson University is extending the project. The federal agency must receive the request with the supporting reasons and revised expiration date at least 30 days before the original expiration date specified on the award. The PI must submit the request to Grants and Contracts Administration. (See Appendix for the format on no-cost time extensions).
Sponsor approved extension requests should be submitted to Grants and Contracts Administration at least 45 days prior to the original end date.
No-cost time extensions may not be requested just to spend unobligated balances.
Occasionally, an active project’s budget requires revision due to unforeseen circumstances. Some sponsors are very rigid, allowing no budget changes without sponsor approval, while others are quite liberal in allowing the PI complete control over the budget. The PI should notify Grants and Contracts Administration as soon as s/he recognizes the need for a budget change. In addition to sponsor requirements, the PI or his/her designee must send a memo justifying and explaining the requested revisions to Grants and Contracts Administration.
If the facilities and administrative cost rate of a project is based on modified total direct costs (MTDC), the transfer of funds from any non-equipment budget class to an equipment budget class will reduce facilities and administrative costs. This reduction is necessary because the University does not charge facilities and administrative costs on equipment in programs using MTDC.
Likewise, transferring funds from equipment to another budget class increases facilities and administrative costs. Fund transfers of this nature could result in a loss of facilities and administrative cost recovery, since the facilities and administrative costs specified in the original award cannot be increased without sponsor approval. Facilities and administrative costs are not affected by budget class changes if the rate is based on total direct costs (TDC).
Requests for budget revisions should be processed through Grants and Contracts Administration, who will forward the requested revision to the sponsor if necessary. When the sponsoring agency delegates approval or disapproval authority to the University administration, the director of Grants and Contracts Administration will act on the re-budget request.
The Department of Health and Human Services (DHHS) has warned that frequent, tardy and unexplained (or inadequately explained) transfers, especially those which involve projects with overruns or unexpended balances, raise serious questions about the propriety of the transfers. Clemson University’s record keeping system and controls are also suspect when costs are frequently transferred.
Documentation of transfers/corrections must contain a justification for the transfer and an explanation of how the error occurred and why the expenditure was not correctly charged the first time. The PI or his/her designee must sign all correction forms. DHHS specifies that an explanation stating "to correct error" or "to transfer to correct project" is neither sufficient nor satisfactory. DHHS also requires the documentation for the adjusting/correcting entries to be readily available at the time of audit.
A federal awarding agency may restrict the transfer of funds among direct cost categories or programs, functions and activities for awards in which the federal share of the project exceeds $100,000 and the cumulative amount of such transfers exceeds or is expected to exceed 10 percent of the total budget as last approved by the federal awarding agency.
Transfers of charges to and between government grants and contracts should be kept to a minimum. Account numbers should be properly reflected on requisitions, appointment forms, time sheets, etc. when initiated and when work orders are placed at service centers within the University.
To help ensure that cost transfers will meet audit requirements, any transfer of cost into or between federal government grants and contracts must meet several criteria to satisfy audit requirements:
Since audit disallowances must be covered by other non-restricted funds in the department, individuals who process the correction should always obtain approval from the chairperson of the department.