Comprehensive reference guide

None

200.407 Prior Approvals

Under any given Federal award, the reasonableness and allocability of certain items of costs may be difficult to determine. In order to avoid subsequent disallowance or dispute based on unreasonableness or non-allocability, the University may seek the prior written approval of the cognizant agency for indirect costs or the awarding agency in advance of the incurrence of special or unusual costs. The request for prior written approval should include the timeframe or scope of the agreement.

(a) 200.201 Use of grant agreements (including fixed amount awards), cooperative agreements, and contracts, paragraph (b)(5);

(b) 200.306 Cost sharing or matching;

(c) 200.307 Program income;

(d) 200.308 Revision of budget and program plans;

(e) 200.332 Fixed amount subawards;

(f) 200.413 Direct costs, paragraph (c);

(g) 200.430 Compensation—personal services, paragraph (h);

(h) 200.431 Compensation—fringe benefits;

(i) 200.438 Entertainment costs;

(j) 200.439 Equipment and other capital expenditures;

(k) 200.440 Exchange rates;

(l) 200.441 Fines, penalties, damages and other settlements;

(m) 200.442 Fund raising and investment management costs;

(n) 200.445 Goods or services for personal use;

(o) 200.447 Insurance and indemnification;

(p) 200.454 Memberships, subscriptions, and professional activity costs, paragraph (c);

(q) 200.455 Organization costs;

(r) 200.456 Participant support costs;

(s) 200.458 Pre-award costs;

(t) 200.462 Rearrangement and reconversion costs;

(u) 200.467 Selling and marketing costs; and

(v) 200.474 Travel cost

The costs most likely to require prior approval are:

200.306 Cost Sharing:

Under ordinary circumstances, cost sharing is not expected for research proposals, nor can it be used as a factor in merit review.  If cost sharing is permitted, however, then prior approval is required to use unrecovered indirect cost to offset the cost-share requirement.

200.308 Revision of budget and program plans:

If the agencies recognize and approve, in general or on a case by case basis, the concept of “expanded authorities” from A-110, then there may be fewer requirements for prior approvals under 200.308.  In any case, a number of requirements for prior approval are likely to remain – 1) a change in the approved Scope of Work, 2) a change in the Key Personnel, 3) the transfer of participant support funds, 4) changes in the approved cost-sharing contribution, and 5) the need for additional funds to complete the project.

200.332 Fixed amount awards:

Prior approval is required to issue fixed-amount subawards up to $150,000, including both direct and indirect costs.

200.413 Direct costs – Administrative and Clerical salaries:

These costs must be explicitly included in the proposal budget (and awarded budget) or receive the prior written approval of the awarding agency.

200.430 Compensation – personal services:

Incidental activities for which supplemental compensation is allowable under written institutional policy must either be specifically provided for in the awarded budget or receive prior written approval from the funding agency.

200.438 Entertainment Costs:

In general, the costs of entertainment are unallowable.  If specific costs, that might otherwise be considered entertainment, have a programmatic purpose, they may be authorized either in the approved award budget or with the prior written approval of the funding agency.

200.439 Equipment and other capital expenditures:

Capital expenditures for improvements to land, buildings, or equipment, which materially increase their value or useful life are unallowable as a direct cost except with the prior written approval of the funding agency.

200.454 Memberships, subscriptions, and professional activity costs:

Costs of membership in any civic or community organization are allowable only with the prior written approval of the funding agency.

200.456 Participant support costs:

Participant support costs are allowable with prior written approval of the funding agency.

200.458 Pre-award costs:

Pre-award costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the prior written approval of the funding agency.

200.474 Travel costs:

Consult with OGCS before including any of the above costs in a proposal budget and PAASFC prior to expending funds in these areas if the specific costs have not received prior approval.

No updates at this time.

See the OGCS and PAASFC websites for specific information about proposing and managing these costs.