Prior Approval Request Policy

1. Purpose of Policy

Federal awarding agencies are authorized, at their option, to waive cost-related and administrative prior written approvals required by the Code of Federal Regulations Title 2: Grants and Agreements Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200). This process gives the recipient expanded authorities.

2. Stakeholders Most Impacted by the Policy

This policy applies to federally funded awards issued under sponsored awards made to Western Michigan University (WMU).

3. Key Definitions

3.1 Expanded Authority:  Authority federal agencies have granted to the University to make minor, non-substantive changes without obtaining additional federal approval.

4. Full Policy Details

When the grant has Expanded Authorities, the PI must complete the WMU University Prior Approval form to make allowable changes.

Depending upon the awarding agency, Expanded Authority may allow changes that are necessary for the completion of the project within the original scope of work and budget.  Expanded Authority only applies to grants and cooperative agreements, and does not automatically apply to subawards.  Examples of Expanded Authorities may include no-cost extensions, re-budgeting of 10% or less between direct cost categories, carry-forward of unobligated funds into subsequent years, and inclusion of costs incurred up to 90-days prior to the initiation of the budget period.

Numerous federal agencies currently allow for Expanded Authority.  The terms and conditions document provided by the awarding federal agency will specify the applicable expanded authority

5. Accountability

5.1 Failure to adhere to these Federal regulations for reporting guidelines in connection with a specific sponsored project may result in the withholding of new awards.

5.2 Failure to follow this Policy and any associated procedures may subject WMU employees to disciplinary action, up to and including dismissal from employment by the University consistent with applicable procedures and Collective Bargaining Agreements.

6. Related Procedures and Guidelines

Prior Approval Request Procedure