Changes to Programs During the Life of an Award

When a grant or contract is awarded in response to a proposal, the sponsor expects the project to be carried out in accordance with the proposed scope of work and budget and sponsors may evaluate the project against the budget at any time. Since the course of research is often uncertain and circumstances can change, sponsors must make provisions for adjusting the scope of work and budget throughout the life of an award. All requests for changes must be in writing and endorsed by your RAS representative.

For Non-Federal sponsored programs (e.g. industry, foundations, foreign government, non-profits), consult the terms of the agreement for guidance as requirements vary depending on the sponsor’s policies. When the award is silent, PIs should follow the guidance below for Federal grants and cooperative agreements.

Federal contracts are restrictive and must be closely monitored.

Federal grants and cooperative agreements often provide more flexibility under Expanded Authorities and PIs have the flexibility to make changes to their awards except as described below.

  • Change in Principal Investigator or in some cases, other Key Personnel
  • PI’s disengagement from the project for more than three months [webpage]
  • Reduction in PI’s level of effort by 25 percent or more from the awarded level [webpage]
    • PI should describe the effort change needed and address whether it will impact the PI’s ability to accomplish the original project objectives
  • Changes in project scope
    • PI should describe the scope change needed, and the impact the change will have on the time line and budget
  • Need for new Subawards to organizations not included in the approval award
    • PI should submit the scope of work and budget along with a justification as to why the subaward organization is uniquely qualified to perform the research
  • Transferring the award to another institution [webpage]
    • PI should discuss plans with the program officer prior to initiating this change; project should undergo formal closeout at MIT, and the PI will re-submit the proposal to the agency under the new institution
  • Transferring of funds budgeted for Participant Support Costs to other categories of expense.
  • Changes in the amount of approved cost-sharing or matching provided by MIT.

Remember to review the sponsor’s specific awards terms and conditions prior to making a change. Ensure changes are consistent with the project objectives and any laws, regulations and guidelines.

All requests for adjustments during the life of the award must originate with the PI and be endorsed and submitted by your RAS representative on behalf of the Institute’s Authorized Representative. If the sponsor does not respond within a reasonable time period, DLCs/PIs are encouraged to follow up directly with the sponsor on NCE requests sent by RAS.  

Reference: Research Terms and Conditions for Federal agencies National Science Foundation Prior Approval Matrix [link to page with PDF]. Note that for awards that fall under OMB’s Uniform Guidance, this Prior Approval Matrix will be replaced by a revised matrix of standard federal Research Terms and Conditions.