OSU GCG 103: Expanded Authority - Budget Changes, Pre-Award Costs & No-Cost Extensions

Purpose

To identify the processing of preaward costs for sponsored programs funded by various federal agencies.

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Applicability

Applies to grants and cooperative agreements, but does not apply to contracts. To determine whether an agreement is a grant, cooperative agreement, or a contract either of these banner screens can be used:

FTMFUND – if the predecessor fund ends in a five, it’s a contract.
FRAGRNT – if grant type box is “C”, it’s a contract. If grant type is a “G”, it’s a grant. If grant type is “A”, it’s a cooperative agreement.

Note: There are other grant types that are not covered under expanded authority.

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Background

Several federal agencies have adopted expanded authority policies that are intended to reduce overhead costs, increase research productivity, and reduce paperwork.

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Definition

Expanded Authority

The authority granted to OSU that waives the prior approval requirements by a sponsoring agency.   Expanded authority is used only for changes that are necessary for the completion of the project within its original scope and original total budget.

Prior Approval Requirements

A Sponsoring Agency's requirement that the Agency approve changes prior to the change occurring.

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Procedures

Budget Changes
Departments may only request changes in:

1. Reallocation of budget line items. (Such changes are accomplished by a budget JV using journal type 1PBB - include proper justification in the text field; the Office of Post Award Administration must approve the JV).
2. Pre-Award setup and costs limited to 90 days prior to start date of award.
3. One-time only, No-cost Extension up to one year.

Examples of changes not covered under expanded authority (written agency approval is required to do any of the following):

• Change student support in the form of fellowships and stipends
• Write subcontracts > than $25,000
• Building Construction changes
• Change F & A rate
• Change in scope of work
• Change of PI  - See website for Sponsored Programs to transfer PI form.

Modification of the Research Work Order is required when expending for a new direct cost line item that was not in the original budget, or to modify the objectives, increase funding levels, or extend the time frame of the award.

Agencies that have given expanded authority are:

ONR – Office of Naval Research  (except no-cost extensions) – these are requested by sending a request with proper justification to the Office of Post Award Administration Manager, to be forwarded to ONR.

NASA – National Aeronautics & Space Administration

NSF – National Science Foundation

USDA/CSREES –  US Dept of AG-Cooperative State Research Education & Extension Service

Note: Expanded Authority has been delegated for CSREES only, not all branches of USDA.)

US-Ed – US Dept of Education

NIH/PHS – National Institutes of Health/Public Health Service

NOAA/US Dept of Commerce – Nat’l. Oceanic & Atmospheric Administration

Note: Expanded Authority has been delegated for NOAA only, not all branches of US-Dept. of Commerce. No rebudgeting direct for F&A or vice versa, unless noted in special terms and conditions.

DOE – US Dept of Energy

USDI – US Dept of Interior  (except rebudgeting)

EPA – Environmental Protection Agency

ARO – Army Research Office

AFOSR – Air Force Office of Scientific Research

Pre-Award Costs

NSF, PHS, NASA, DOE, NOAA, CSREES, AFOSR, ARO, and ONR: Approval may be granted for expenditure of funds up to 90 days prior to the expected start date of a new grant or cooperative agreement. Advance funding must be necessary for the effective and economical conduct of the project.  Pre-award costs will not be approved unless a Department Head/Chair or a Dean/Director guarantees to reimburse the university in the event the grant or cooperative agreement is not received.  See GCG 408: List of Acronyms.

Request pre-award costs using OPAS form.

ALL OTHER AGENCIES OR SPONSORS: OSU is not authorized to approve pre-award costs for other agencies. However, it may be possible for the Office of Post Award Administration to set up a “pending index” for awards which have passed the start date, but for which the award document has not yet been received or fully executed. See GCG 105: Cost Accounting Standard Guidelines, #12 in Grants & Contracts section.

Normally, expenditures may not be charged against sponsored programs before the effective date of a sponsored program agreement. However, some federal agencies allow requests for preaward expenditures to be reviewed and approved within OSU.

No-Cost Extensions

OSU can grant a single no-cost extension of time up to 12 months. The request must be submitted to Office of Post Award Administration 45 days prior to the expiration date of the project.  The Office of Post Award Administration must notify the agency within 30 days of the extension and prior to the expiration date of the project.  Use the OPAS form.

NSF, NIH/PHS, NASA, NOAA, ARO, AFOSR and DOE: OSU may approve a one-time no-cost extension of up to one year beyond the original expiration date.  Request must be made prior to current expiration date of grant.  Review of request will consider summary of progress, estimate of funds remaining, and plans for the completion of the project.  See GCG 408: Acronyms of Agencies.

Such an extension may be made when one of the following applies:

1. additional time is required to assure completion of the original approved project scope or objectives; or
2. continuity of grant support is required while a competing application is under review; or
3. the extension is necessary to permit an orderly phase out of a project that will not receive continued support. The fact that funds remain in the grant is not in itself justification for a no-cost extension. The Office of Post Award Administration must notify the Grants Officer 30 days prior to the original expiration date.

Specific for: CSREES: up to a maximum potential award period not to exceed five years. The award period will commence as of the effective date cited in the grant; however, if OSU has elected to charge allowable pre-award costs under the grant, the award period will commence, for the purpose of determining the beginning of the maximum potential five year award period, on the date the first pre-award cost is incurred.

Specific for: NOAA: Requests not received at least 30 days before the end date will not be approved.

No cost extensions cannot be processed through OPAS if the award is past the end date. The request for extension must be made by the PI, in writing, and submitted to the contracting office of the sponsoring agency. The letter should be signed by the PI and countersigned by the Office of Post Award Administration Manager.

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