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

Grant, Contract & Gift Accounting Manual
Section 100: General Administration of Award
Revised: 08/20/2013

Purpose

To describe the processing of pre-award costs, budget changes and no-cost extensions for sponsored programs funded by various federal agencies. To identify the federal agencies who have granted OSU expanded authority.

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.

Background

Several federal agencies have adopted expanded authority policies that waive the normally required sponsor prior approval for specific actions.  Expanded authority is intended to reduce overhead costs, increase research productivity, and reduce paperwork.

Definition

Expanded Authority

The authority granted to OSU that waives certain prior approval requirements by a federal 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.

Policies and Procedures

Federal agencies that have given expanded authority are:

ONR – Office of Naval Research (except no-cost extensions)

NASA – National Aeronautics & Space Administration

NSF – National Science Foundation

USDA/NIFA (formerly CSREES)  Note: Expanded Authority has been delegated for NIFA (formerly 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

EPA – Environmental Protection Agency

ARO – Army Research Office

DOT - Department of Transportation  

BUDGET CHANGES

A reallocation of budget line items may be requested.  For agencies who have granted expanded authority, 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 (OPAA) must approve the JV. 

PRE-AWARD COSTS

Normally, expenditures may not be charged against sponsored programs before the effective date of a sponsored agreement. However, some federal agencies allow requests for pre-award expenditures to be reviewed and approved within OSU via expanded authority.

NSF, NASA, USDA-NIFA (formerly CSREES), NOAA, NIH/PHS, ARO,DOE, DOT, EPA, US-ED 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.  Request pre-award costs using Pre-Award Cost form. 

ALL OTHER AGENCIES OR SPONSORS: OSU is not authorized to approve pre-award costs for other agencies. However, it may be possible for OPAA to set up a “pending index” for awards anticipated to be funded, but for which the award document has not yet been received or fully executed. See GCG 105: Cost Accounting Standard Guidelines, #4 in Grants & Contracts section.

NO-COST EXTENSIONS

NSF, NASA, USDA-NIFA (formerly CSREES), NOAA, NIH/PHS, ARO, DOE, DOT, EPA and US-ED: OSU, via expanded authority approve a one-time no-cost extension of up to one year beyond the original expiration date.  The request must be submitted to OPAA at least 30 days prior to the expiration date of the project.  OPAA must notify the agency at least 10 days prior to the expiration date of the project. Review of request will consider summary of progress, estimate of funds remaining, and plans for the completion of the project. Complete the OPAS/No-Cost Extension form and submit to the OPAA Grant Accountant responsible for the specific agency. 

Examples of when such an extension may be requested are as follows:

  1. additional time is required to assure completion of the original approved objectives; or
  2. continuity of grant support is required while a competing application is under review; or
  3.  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.

Specific for: USDA - NIFA (formerly 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 ONR: Complete the OPAS/No-Cost Extension form and forward to the OPAA Grant Accountant for review and processing.  Upon approval, the Assistant Director of Business Affairs/OPAA will forward the request to ONR via e-mail.

No cost extensions cannot be processed under expanded authority if the award is past the end date.  The OPAS/No-Cost Extension form must be completed and the request for extension must be made by the PI, in writing, on letterhead. The letter should be signed by the PI and include a blank line so that it can be countersigned by the Assistant Director of Business Affairs/OPAA.  OPAA will forward to the sponsoring agency.

EXAMPLES OF CHANGES NOT COVERED UNDER EXPANDED AUTHORITY (written agency approval is required to do any of the following):