PRIOR APPROVAL REQUIREMENTS FOR FEDERAL AWARDS

Federal Grant Prior Approval Categories

There are three categories of federal agency prior approval authorities for postaward grants administration: Federal Demonstration Partnership (FDP), PHS Expanded Authorities for Research Activities, and Other Awards Not Eligible for Either FDP or Expanded Grant Authorities.

Federal Demonstration Partnership (FDP)

The FDP is a cooperative initiative among federal agencies and institutional recipients (including UCSF) of federal grants. It was established to increase research productivity by streamlining the administrative process and minimizing the administrative burden on principal investigators while maintaining effective stewardship of federal funds. An FDP grant is defined as a grant award from the following agencies: AFOSR, Army Research Office, Army Medical Research & Development Command, USDA, DOE, EPA, NASA, NIH (not all grant mechanisms are included), NSF, and ONR.

NIH Grant Awards Under FDP

The “Remarks” section on the Notice of Grant Award will indicate whether the grant is awarded under the terms and conditions of the FDP. However, an awarding component may specifically exclude a grant award from the FDP when considered necessary by programmatic and/or administrative reasons. Exceptions to any policy are normally stated in the “Remarks” section on award notices.

For certain funding mechanisms, NIH has implemented streamlined requirements for progress report submission, the Notice of Grant Award (NGA), and financial reporting. Known as the Streamlined Noncompeting Award Process (SNAP), NIH routinely applies SNAP to most Research Project (R-series) awards (except R35s, R41s, and R43s), and Research Career (K-series) awards. NIH grantees are expected to follow the SNAP process for those awards that are issued under the SNAP, as indicated on the NGA.

For NIH Awards with award dates on or after 12/1/03 refer to NIH Grants Policy Statement (12/03) Part II: Terms and Conditions of NIH Grant Awards, Subpart A: General, Administration Requirements for prior approval requirements.

Other Participating Federal Agency Grant Awards Under FDP

For other participating agencies under the FDP, review the notice of grant award for mechanism of support and terms of the award. Refer to the FDP matrix, revised April 2004, for a summary of FDP federal agency prior approval requirements for the ten participating federal agencies.

PHS Awards

PHS has implemented expanded authorities for grantee organizations, designed to “waive approval of certain actions which had previously required awarding office prior approval.” These PHS expanded authorities offer many, but not all, of the FDP authorities to grants from PHS agencies other than NIH. Since UCSF does participate in the FDP, only PHS grants awarded UCSF from agencies other than NIH, such as FDA, CDC, etc., would come under PHS Expanded Authorities. Subcontracts from non-FDP participating institutions are also under Expanded Authorities. All awards made under the Expanded Authorities will explicitly state so on the Notice of Grant Award. Any PHS award that does not reference either the Federal Demonstration Partnership or Expanded Authorities is administered under the PHS Regular Authorities for post-award expenditures.

The PHS matrix supersedes the version that was dated April 21, 1998. A copy of the updated matrix can additionally be found on the PHS Matrix web page.

Note that any of these prior approval authorities can be superseded by special restrictions written on the Notice of Grant Award. Therefore, award notices must be reviewed for restrictions before making expenditures that might require prior approval.