Changes to Programs During the Life of an Award

When an award is issued in response to a proposal, it is with the expectation the project will be carried out in accordance with the proposed scope of work and budget and consistent with project objectives. Sponsors may evaluate the project against the budget at any time. Though the course of research is often uncertain and circumstances can change, many changes require sponsor approval.

Requesting Approval for Changes

For all requests requiring sponsor prior approval for changes during the life of the award:

  1. PI notifies RAS of the change.
  2. RAS endorses and submits the change on behalf of the Institute’s Authorized Representative.
  3. If the sponsor does not respond within a reasonable time period, DLCIs/PIs are encouraged to follow up directly with the sponsor on any requests sent by RAS. 

Changes Requiring Approval

Non-federal Sponsored Programs

For industry, foundations, foreign government, and non-profit sponsors, consult the terms of the agreement for guidance. When the award is silent, follow MIT standard terms and policies on changes.

Federal Contracts

Federal contracts are restrictive and must be closely monitored. Any change will have to be approved by the federal contracting office.

Federal Grants and Cooperative Agreements

Federal grants and cooperative agreements often provide more flexibility under Expanded Authorities and PIs have some flexibility to make changes to their awards. 

Examples of circumstances requiring sponsor approval (and in some cases, updates in KC):

  • Change in PI (or in some cases, other Key Personnel)
  • PI absence from project for more than 3 months
  • Reduction in PI’s level of effort (or, in some cases, effort of Key Personnel) by 25 percent or more. See Managing Key Personnel for the Life of the Award
  • Transferring the award to another institution
    • PI should discuss plans with the program officer prior to initiating this change
    • Project should undergo formal closeout at MIT
    • PI will re-submit the proposal to the agency under the new institution
  • Changes in project scope: When requesting approval, describe the change and its impact on the timeline and budget
  • New subawards to organizations not included in the approved award

    Re-budget of awarded Participant Support Costs (a restricted category most often included on NSF awards) to other categories

  • Changes in the amount of approved cost-sharing or matching provided by MIT

For a full list, see Federal Prior Approval Matrix.

Updated March 25, 2024