Prior Approval and Changing a Grant

Prior approval is required before a federal grant recipient changes the scope or objectives of a project, changes named key personnel, transfers substantive programmatic work, adds costs the cost principles gate, needs more federal funds, or extends the period of performance beyond an authorized one-time extension.

Current figures — verified 2026-08-11

Item	Value	Source
Project director disengagement trigger	More than three months away from the project	2 CFR 200.308(f)(3)
Project director effort reduction trigger	25 percent reduction in time and effort over the period of performance	2 CFR 200.308(f)(3)
No-cost extension request and notice lead time	At least 10 calendar days before the period of performance ends	2 CFR 200.308(f)(10), (g)(2)
One-time no-cost extension length	Up to 12 months	2 CFR 200.308(g)(2)
Pre-award cost window without prior approval	90 calendar days before the federal award date	2 CFR 200.308(g)(1)
Agency response target on a revision request	Should notify within 30 days of receipt	2 CFR 200.308(d)
Rebudgeting restriction conditions	Federal share above the simplified acquisition threshold and cumulative transfer above 10 percent of the total budget including cost share	2 CFR 200.308(i)
Simplified acquisition threshold	$350,000	FAR 2.101, 48 CFR 2.101
Special purpose equipment prior approval trigger	Unit cost of $10,000 or more	2 CFR 200.439(b)(2)

These figures change. Verify against the linked source before relying on them. Report an outdated figure

Key takeaways

• Prior approval means before, and retroactive approval is discretionary.
• Ten categories of change always require written agency approval.
• The award terms can withhold flexibilities the regulation otherwise grants.
• Only the grants officer can approve; the program officer advises.
• Unapproved changes become disallowed costs, repayable by the recipient.

When do you need prior approval to change a grant?

Prior approval is needed whenever a proposed change falls into one of the categories enumerated in the Uniform Guidance, whenever the award’s own terms add a trigger, or whenever a cost principle conditions allowability on approval. The governing rule is 2 CFR 200.308, which also requires recipients to report deviations from the approved budget, project or program scope, or objectives — one of the core operating disciplines of managing the award.

The approved budget is the reference point. 2 CFR 200.308(a) defines it as the document that “summarizes the financial aspects of the project or program as approved during the Federal award process,” and it may cover the federal share alone or the federal and non-federal shares together. Everything you may spend without asking sits inside that document, which is one reason the approved budget deserves attention while reading the Notice of Award rather than at the first variance.

Agencies are constrained here too. Unless the guidance specifies otherwise, a federal agency “must not impose additional prior approval requirements without OMB approval” (2 CFR 200.308(e)). What an agency can do is withhold, in the terms of a specific award, a flexibility the regulation would otherwise give you — which is why the award document, not the regulation alone, is the operative source.

Which grant changes always require prior written approval?

Ten categories of change require prior written approval from the federal agency or pass-through entity under 2 CFR 200.308(f), regardless of whether any money moves. Each exists because the change would alter what the agency evaluated and funded.

• Change in scope or objective. Required “even if there is no associated budget revision requiring prior written approval.” The agency funded a specific project; a different project is a different decision.
• Change in key personnel. Applies to employees and contractors identified by name or position in the award. Merit review often turned on who would do the work.
• Project director disengagement or effort reduction. Absence beyond the period in the figures above, or an effort reduction at or beyond the stated percentage, by the approved project director or principal investigator.
• Costs requiring approval under the cost principles. Unless waived by the agency. The gated items are listed at 2 CFR 200.407 and include cost sharing, program income, fixed amount subawards, certain compensation and fringe items, equipment and capital expenditures, fundraising and investment management costs, insurance, organization costs, pre-award costs, and travel.
• Transfers out of participant support costs. Moving funds budgeted for participants into other categories.
• Subaward activities not proposed and approved. Transferring substantive programmatic work to a third party that the award did not contemplate. A change of subrecipient requires approval only where the award terms say so, and the rule does not reach procurement transactions for goods and services.
• Change in total approved cost sharing. Match is a term of the award, not an internal target.
• Need for additional federal funds, transfers between construction and non-construction work, and no-cost extensions beyond an authorized one-time extension. Requests for a no-cost extension should be submitted within the lead time in the figures above.

Agencies publish their own interpretations of the fuzziest category. NIH treats “transfer of the performance of substantive programmatic work to a third party,” changes to originally approved specific aims, shifts in human subjects classification, and significant rebudgeting as indicators of a change in scope (NIH Grants Policy Statement, Section 8.1.2).

Which grant changes can you make without asking?

Some prior approvals are waivable, and agencies commonly waive them. 2 CFR 200.308(g) authorizes a federal agency to waive cost-related and administrative prior approvals outside the ten mandatory categories, and names three that recipients rely on most.

Pre-award costs may be incurred within the window in the figures above ahead of the federal award date, with anything earlier requiring approval. The caveat is absolute: “All costs incurred before the Federal award date are at the recipient’s own risk,” and the agency is not required to reimburse them if no award issues or the award is smaller than expected (2 CFR 200.308(g)(1)).

A one-time extension of the period of performance may be initiated by the recipient where the award terms authorize it, for the length shown in the figures above. Notification is still mandatory: the recipient must notify the agency in writing with supporting justification and a revised period of performance within the stated lead time. Three conditions pull the extension back under prior approval — the terms prohibit it, the extension requires additional federal funds, or it involves a change in approved scope. One sentence closes the obvious loophole: “A one-time extension may not be exercised for the sole purpose of using unobligated balances” (2 CFR 200.308(g)(2)).

Carrying unobligated balances forward to subsequent budget periods is the third waivable authority (2 CFR 200.308(g)(3)). For research awards, the waiver is automatic: prior approval for the actions in paragraph (g) “are automatically waived for Federal awards that support research unless stipulated in the Federal agency’s regulations or terms and conditions of the Federal award” (2 CFR 200.308(h)). Automatic carryover is a flexibility agencies frequently withhold on a specific award, so the award document decides.

How much can you move between grant budget categories?

Rebudgeting between direct cost categories is generally permitted, and the commonly cited percentage limit is a permission granted to agencies rather than a self-executing prohibition. 2 CFR 200.308(i) says a federal agency “may also, at its option, restrict the transfer of funds among direct cost categories” only when two conditions hold together: the federal share of the award exceeds the simplified acquisition threshold, and the cumulative transfer exceeds or is expected to exceed the percentage of the total budget shown in the figures above, including cost share, as last approved.

Both conditions matter. Below the threshold set in the Federal Acquisition Regulation (48 CFR 2.101), the restriction does not attach at all. Above it, the restriction applies only if the agency exercised the option in the award terms. Whether rebudgeting binds a particular recipient is therefore a question about the award document, not about the regulation.

Three limits survive regardless of the percentage. A transfer may never cause a federal appropriation to be used for a purpose inconsistent with the appropriation (2 CFR 200.308(i)). A transfer out of participant support costs always requires approval. And a transfer that changes the scope requires approval even where every dollar stays within an approved category — a point that also constrains how allowable, allocable, and reasonable costs are charged in practice.

Some rebudgeting crosses into a separately gated cost. Capital expenditures for special purpose equipment are allowable as direct costs only where items at or above the unit cost in the figures above have prior written approval (2 CFR 200.439(b)(2)). A reallocation into equipment is two decisions, not one.

Who can approve a change to a grant?

Approval authority sits with the agency’s grants officer, not with the program officer. Both are usually named on the award, and both are usually consulted, but only one of them can obligate the government. NIH states the division without ambiguity: the Grants Management Officer “is the focal point for receiving and acting on requests for NIH prior approval or for changes in the terms and conditions of award, and is the only NIH official authorized to obligate NIH to the expenditure of Federal funds or to change the funding, duration, or other terms and conditions of award” (NIH Grants Policy Statement, Section 2.1.1).

The program officer’s role is real but advisory. Program staff assess whether a proposed change remains within the funded aims and whether the science or service model still holds. That assessment usually precedes the grants officer’s decision on a change in scope, and a favorable program conversation is not an approval.

Authority on the recipient’s side is equally specific. Requests come from the organization’s authorized representative, not from the project director acting alone, because the request binds the organization. Governance that works looks like this: the project director identifies the proposed change, the grants administrator classifies it against the trigger list, the authorized representative submits it, and the written response is filed with the award.

The discipline is to get everything in writing. A verbal assurance is not an approval, does not survive staff turnover, and is not available to an auditor three years later. Where a subaward is involved, the pass-through entity holds the same approval role toward its subrecipient that the agency holds toward the prime, as described under subrecipient monitoring and pass-through funding.

What should a prior approval request contain, and what happens without one?

A prior approval request should contain the specific change proposed, the regulatory or award-term trigger it falls under, the justification, the budget effect by cost category, the effect on the approved scope and objectives, and the revised period of performance where relevant. Budget information must use the same format used in the application unless the agency approved an alternative (2 CFR 200.308(c)).

Timing is set by the regulation but not guaranteed by it. The agency “should notify the recipient or subrecipient whether the revisions have been approved within 30 days of receipt of the request,” and must inform the recipient in writing when a decision can be expected if a longer review is needed (2 CFR 200.308(d)). Plan on the stated target as a floor rather than a ceiling, and submit before the change is operationally necessary rather than after.

Proceeding without approval is expensive, and the burden falls on the recipient. An unapproved change puts the associated activity outside the approved scope, which makes the associated cost unallocable to the award. Agencies and pass-through entities may temporarily withhold payments until corrective action is taken, disallow costs for all or part of the activity, suspend or terminate the award in whole or in part, initiate suspension or debarment proceedings, and withhold further federal funds including continuation funding (2 CFR 200.339). A disallowed cost becomes a receivable the organization pays from unrestricted funds.

Retroactive approval exists but is discretionary. Nothing in the Uniform Guidance obliges an agency to bless a completed action, and an agency that does so has already learned something about the recipient’s controls. The cheapest compliance action available in grants management is an email to the grants officer before the change happens.

This article is general information about federal prior approval requirements, not legal or accounting advice. Approval triggers, thresholds, and delegated authorities vary by agency and by award; confirm them with the awarding agency’s grants officer against your own award terms.

Frequently asked questions

What counts as a change in scope on a federal grant?

A change in scope alters what the agency evaluated and funded: the aims, objectives, direction, target population, or method of the project. Agencies also treat transfer of substantive programmatic work to a third party and significant rebudgeting as indicators. Approval is required even where no budget revision is needed.

Can you charge costs incurred before the grant start date?

Within a defined pre-award window, where the agency has waived the approval requirement, and entirely at the recipient’s own risk. Costs incurred earlier than that window require written approval, and approved pre-award costs must be charged to the initial budget period unless the agency or pass-through entity specifies otherwise (2 CFR 200.458).

How does a no-cost extension work?

Where the award terms authorize it, a recipient may initiate a one-time extension of the period of performance without prior approval, with written notice, justification, and a revised period of performance filed before the deadline. Extensions requiring more funds, changing scope, or prohibited by the terms need approval.

Do you need approval to move money between budget categories?

Only where the award terms impose the restriction and both regulatory conditions are met. Transfers out of participant support costs, transfers that change scope, and transfers into cost items gated by the cost principles require approval regardless of the percentage moved.

What is the difference between the program officer and the grants officer?

The program officer oversees the programmatic and technical side and advises on whether a change stays within the funded aims. The grants officer holds the delegated authority to obligate funds and to change the terms of the award. Only the grants officer’s written decision is an approval.

What happens to costs incurred without required prior approval?

Costs associated with an unapproved change are subject to disallowance, and the recipient repays them. Agencies may also withhold payments, impose additional conditions on future awards, suspend or terminate the award, and withhold continuation funding. Documentation that the change was beneficial does not cure the missing approval.

Related topics

• Managing the Award — the hub for reporting, prior approval, monitoring, audit, and closeout
• Grant Reporting Requirements
• The Single Audit
• Grant Termination, Suspension, and Appeals

Sources

1. Electronic Code of Federal Regulations, 2 CFR 200.308, “Revision of budget and program plans.” https://www.ecfr.gov/current/title-2/section-200.308 (accessed 2026-08-11)
2. Electronic Code of Federal Regulations, 2 CFR 200.407, “Prior written approval (prior approval).” https://www.ecfr.gov/current/title-2/section-200.407 (accessed 2026-08-11)
3. Electronic Code of Federal Regulations, 2 CFR 200.439, “Equipment and other capital expenditures.” https://www.ecfr.gov/current/title-2/section-200.439 (accessed 2026-08-11)
4. Electronic Code of Federal Regulations, 2 CFR 200.339, “Remedies for noncompliance.” https://www.ecfr.gov/current/title-2/section-200.339 (accessed 2026-08-11)
5. Electronic Code of Federal Regulations, 2 CFR 200.208, “Specific conditions.” https://www.ecfr.gov/current/title-2/section-200.208 (accessed 2026-08-11)
6. Electronic Code of Federal Regulations, 2 CFR 200.211, “Information contained in a Federal award.” https://www.ecfr.gov/current/title-2/section-200.211 (accessed 2026-08-11)
7. Electronic Code of Federal Regulations, 2 CFR 200.458, “Pre-award costs.” https://www.ecfr.gov/current/title-2/section-200.458 (accessed 2026-08-11)
8. Electronic Code of Federal Regulations, 2 CFR 200.1, “Definitions” (period of performance; budget period; simplified acquisition threshold). https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-A/section-200.1 (accessed 2026-08-11)
9. Electronic Code of Federal Regulations, 48 CFR 2.101, “Definitions” (simplified acquisition threshold). https://www.ecfr.gov/current/title-48/section-2.101 (accessed 2026-08-11)
10. National Institutes of Health, NIH Grants Policy Statement, Section 8.1.2, “Prior Approval Requirements.” https://grants.nih.gov/grants/policy/nihgps/HTML5/section_8/8.1.2_prior_approval_requirements.htm (accessed 2026-08-11)
11. National Institutes of Health, NIH Grants Policy Statement, Section 2.1.1, “NIH and HHS Staff.” https://grants.nih.gov/grants/policy/nihgps/html5/section_2/2.1.1_nih_and_hhs_staff.htm (accessed 2026-08-11)
12. National Institutes of Health, NIH Grants Policy Statement, Section 8.1.1, “NIH Standard Terms of Award.” https://grants.nih.gov/grants/policy/nihgps/HTML5/section_8/8.1.1_nih_standard_terms_of_award.htm (accessed 2026-08-11)