Key Facts
- Core list is in 2 CFR 200.308. Scope change, key personnel change, no-cost extension, additional funds, subaward of substantive work, certain budget changes.
- The cost principles add more. Subpart E flags items like equipment, foreign travel, and participant support that may need approval even if the money's already in your budget.
- Approval must be in writing from the authorized agency official — usually the Grants Management Officer, not your program officer. Verbal "okays" don't count.
- 10% rule of thumb for budget transfers — many awards allow rebudgeting under a cumulative 10% threshold, but this is an expanded authority that not every award grants.
- Skipping it means disallowance. Costs incurred without required approval can be clawed back, regardless of whether the activity itself was reasonable.
Summary
A federal grant is an agreement to do a specific thing, a specific way, with a specific budget. When you want to change one of those things in a meaningful way, the agency often needs to sign off first. That's prior approval. The master list is in 2 CFR 200.308, but it's not the whole list — the cost principles in Subpart E sprinkle additional prior-approval triggers throughout, and your specific award terms can add even more.
The reason to take this seriously is simple. If you incur a cost or make a change that required approval and you didn't get it, the agency can disallow the cost. It doesn't matter that the activity was reasonable, or that you would have gotten approval if you'd asked. The failure to ask is itself the problem. Ask first. It's almost always faster and cheaper than asking forgiveness.
Change in Scope — The One That Hurts Most
Of everything on the prior-approval list, change of scope is the one that does the most damage when you get it wrong, because it goes to the heart of what the agency funded. Under 200.308(c)(1), any change in the scope or objective of the project requires prior written approval — full stop.
So what's a change in scope? It's a substantive departure from the aims the agency reviewed and funded. Changing your target population from rural seniors to urban youth. Dropping a major aim because it turned out to be infeasible. Pivoting the research approach. Shifting from a service-delivery model to a research model. These are scope changes. The agency funded a specific project, and you're now proposing to do a meaningfully different one.
What's not a scope change? Refining your recruitment strategy, adjusting a timeline within the project period, swapping one survey instrument for a comparable one. The project is still fundamentally the thing they funded. The grey area in between is real, and the safe move is to email your program officer with a short description and ask whether they consider it a scope change. Get the answer in writing. If they say it's fine, you've got documentation. If they say it needs formal approval, you've avoided a disaster.
Key Personnel Changes
Under 200.308(c)(2) and (c)(3), you need prior approval to change the approved principal investigator or project director, or if that person will be disengaged from the project for a substantial period — many agencies define this as more than three months — or will reduce their time devoted to the project by 25% or more from what the award assumed.
The logic is that the agency funded a project led by specific people with specific qualifications. If the PI leaves, the agency wants to evaluate whether the replacement can deliver. This catches organizations off guard when a key person resigns mid-project. You can't just slot in a replacement and keep going. You notify the agency, propose the new person with their qualifications, and wait for approval. Some awards name other key personnel beyond the PI; changes to anyone on that named list trigger the same requirement.
GrantMetric Analysis
- Your program officer can't approve anything — and that trips people up constantly. The program officer is your relationship and your technical contact, and they'll often tell you informally "yeah, that sounds fine." But prior approval is a Grants Management Officer function. It's the GMO who signs, in writing, on agency letterhead or through the official system. A friendly email from your program officer is not prior approval. Get the formal action before you act, every time.
- Expanded authorities are a gift, but read the fine print. Many awards — especially research grants under NIH and NSF — grant "expanded authorities" that let you do things like a one-time no-cost extension and certain rebudgeting without prior approval. People hear "expanded authorities" and assume they can do anything. Not true. The authorities are specifically enumerated, scope changes are always excluded, and the 10% rebudgeting freedom usually has carve-outs (participant support, equipment, foreign travel). Know exactly which authorities your award grants.
- Request early — agencies are slow and silence is not approval. Prior approval requests can take weeks. If you need a change effective by a certain date, submit well ahead. And never interpret a non-response as a yes. If the deadline is approaching and you haven't heard back, follow up — don't proceed on the assumption that they would have said yes. Acting before written approval arrives is acting without approval.
Budget Reallocation and the 10% Rule
Moving money between budget categories — rebudgeting — is governed by 200.308 and your award terms. The common rule of thumb is that cumulative transfers exceeding 10% of the total approved budget require prior approval. But "rule of thumb" is doing real work in that sentence. Some awards apply the threshold, some don't grant the freedom at all, and the base it applies to varies.
Certain categories are protected regardless of the 10% threshold. Participant support costs (defined in 200.1) generally can't be repurposed to other categories without prior approval, even small amounts. Direct-to-indirect shifts are restricted. And adding a budget category that wasn't in your approved budget — like buying equipment you didn't propose — frequently needs approval on its own. The safe approach: before any meaningful rebudgeting, check whether your award grants the expanded rebudgeting authority and whether the category you're touching is restricted.
Prior Approval Hiding in the Cost Principles
Here's what people miss. 200.308 isn't the only place prior approval lives. Subpart E — the cost principles — embeds prior-approval requirements in individual cost items. Equipment purchases not in the approved budget may need approval (and intersect with 200.439). Foreign travel often requires specific approval. Pre-award costs incurred before the award start date need approval under 200.458. Participant support costs are restricted under 200.456. Selling and marketing costs, certain memberships, and others carry their own conditions.
So when you're about to incur an unusual cost, don't just check whether it's in your budget. Check whether the specific cost item in Subpart E carries a prior-approval flag. The regulation buries these, and "it was in our approved budget" doesn't always clear a cost that also needs separate item-level approval.
Prior Approval Checklist
- Is it a scope change? If the project would become meaningfully different from what was funded, stop and request approval.
- Is a named key person changing? PI/PD change, 3+ month disengagement, or 25%+ effort reduction all require approval.
- Does your award grant expanded authorities? Check exactly which ones — never assume the broadest reading.
- Is the budget transfer over 10% or in a restricted category? Participant support and equipment are common traps.
- Does the cost item itself need approval? Check Subpart E for foreign travel, equipment, pre-award costs, participant support.
- Get it in writing from the GMO. Submit early, keep the approval, and don't act until it's in hand.