140. Prior Approval Requests
By the end you'll be able to
- Identify the prior approval triggers in 2 CFR 200.308 and agency-specific terms.
- Distinguish changes that require prior approval from those that do not.
- Draft a clean written prior approval request to the grants management official.
- Treat prior approval as a workflow rather than an afterthought.
Prior approval is the federal mechanism that requires recipients to obtain written permission from the awarding agency before making certain changes to an active award. Under 2 CFR 200.308 and the agency-specific terms layered on top, prior approval is typically required for changes in scope or objectives, changes in key personnel named in the NoA, the absence of a key person for more than three months or a 25 percent reduction in their effort, and budget revisions that move more than 10 percent of the total budget between cost categories.
In this lesson you will learn to identify the prior approval triggers in your award, draft a clean written request, and route it to the correct grants management official before taking action. You will also learn the prior approval categories that come up most often: no-cost extensions, carryover of unobligated balances, equipment purchases above thresholds, foreign travel, pre-award costs incurred up to 90 days before the start date, and rebudgeting that affects approved cost-sharing.
By the end you should treat prior approval as a workflow, not an afterthought. Acting first and asking later almost always results in disallowed costs, because the agency has no obligation to retroactively bless decisions you made without their consent. A thirty-minute request preserves thousands of dollars of allowable spending.
Common mistakes
These are the traps learners hit most often on this topic. Knowing them in advance is half the fix.
Acting first and asking later.
Federal agencies have no obligation to retroactively bless decisions you made without their consent, so unauthorized changes routinely become disallowed costs.
Routing the request to the program officer instead of the grants management official.
Programmatic conversations are useful, but only the grants management official can issue binding prior approval. Verbal approvals are not enforceable.
Practice problems
Try each on paper first. Click Show solution only after you've made a real attempt.
- Problem 1The principal investigator wants to extend the project six months at no additional cost. Walk through how to handle the request.
Show solution
This is a no-cost extension request. Under 2 CFR 200.308, recipients can frequently exercise a one-time first extension of up to 12 months without prior approval if certain conditions are met, but you must notify the awarding agency at least 10 days before the period of performance end date, and many agencies require explicit approval. Submit a written request that includes the original end date, the proposed new end date, a justification (work remaining, programmatic reason for the additional time), confirmation that no additional funds are needed, and an updated milestone schedule. Send it well before the end date and obtain written approval before relying on the new period.
Practice quiz
- Question 1Which budget rebudgeting threshold generally triggers prior approval under 2 CFR 200.308?
- Question 2Which personnel change typically requires prior approval?
Lesson 140 recap
Prior approval is a workflow with clear triggers (scope changes, key personnel changes, rebudgeting above 10 percent, no-cost extensions, pre-award costs). A thirty-minute written request to the right official preserves thousands of dollars of allowability.
Coming next: Lesson 141 — Audit Readiness
Next, we shift from individual transactions to the comprehensive audit posture every recipient must maintain.
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