Project Modification Request (PMR)

The online PMR system streamlines prior approval requests from the department/PI to the College Research Office, then on to C&G or Sponsored Programs. The online PMR system also provides accountability for all who manage and process PMRs.

Questions to ask yourself when preparing a Project Modification Request (PMR)

Domestic travel and foreign travel are common activities that Principal Investigators (PIs) and research staff may engage in during an award. Sponsored travel must be justified, well documented, in compliance with the sponsor requirements and must be incurred during the period of the award.

Traveler requirements:

  • The traveler must have effort on the project.
  • Travel charges related to the traveler must be paid or cost-shared from the sponsored award.
  • Travel costs must be:
    • Allowable: Travel must be allowed under the terms of the award.
    • Allocable: The travel is necessary to fulfill the programmatic objectives of the award charged for the travel expense.
    • Reasonable: The travel costs are reasonable and not excessive; examples of excessive include stays at luxury hotels, expensive restaurants, the use of limousines, etc. The trip must specifically benefit the project.
    • The trip must have prior written approval on file.
    • Funds must be available for the travel.
    • If not in approved budget, agency approval is required.
    • Is foreign travel being charged to a federal award? If yes, foreign travel must be in compliance with the Fly America Act.

Questions referenced when PMR is reviewed:

  • Is travel listed or budgeted in the award?
  • What is the purpose of the award?
  • How does travel relate to the purpose of the award?
  • Who (traveler), What (seminar, etc.), Where (location), When (Dates — is the travel within the dates of the award) and why (purpose)?
  • Is this “Prior” approval? Has the travel already taken place?
  • Is agency approval needed?

While sponsors expect principal investigators (PI) to complete projects by the stipulated end date, occasionally extra time is needed. A no-cost extension gives the PI extra time to complete the scope and objectives of the project without additional funds being provided by the sponsor. Although request may not be made for the sole purpose of spending remaining funds, you may expend remaining funds during the no-cost extension period. In the event your request is not approved, costs incurred after the end date would not be allowable.

The justification for the request must include:

  • Information regarding the current project end date to the expected new end date
  • The amount of additional time requested
  • The reason for the request:
    • You should explain the scientific need for the extension
    • The reason for the delay
    • What remains to be completed

When requesting an NCE, sponsor’s terms and conditions must be adhered to. This may require additional forms, budget or justification. When a request is submitted for a project with a Subcontract budgeted within the Prime, the NCE request will apply to that Prime/Parent only. It will not extend the Subcontract. To extend the Subcontract, a Subaward (Modify) PMR request must be submitted.

Note: The SPARCS Office will be responsible for entering the NCE information into the agency databases, which include but are not limited to Fastlane, NASA, eRA Commons, Grants Online and Grant Solutions.

Questions referenced when PMR is reviewed:

  • Why is it needed (detail and technical justification)?
  • Was there a delay and why? (What was it?)
  • What remains to be completed? Describe in detail.
  • Is this a first NCE request?
  • What is the current ending date?
  • Do we have a deadline to request the extension by?
  • Is this a RUSH? Is agency approval needed?
  • Are there any segments (set via BA148) that will need to be extended also?

Questions referenced when PMR is reviewed:

  • What is the end date on the prime?
    • Sub-accounts/subcontracts may not be extended past the prime.
    • Watch end date — you may not want the sub account/subcontract to have the same end date as prime for reporting deadlines.
  • What college is the prime in?
  • Is this a sub-contract or sub-award?
    • If subcontract: Is a subcontract request/modification form attached/completed and approved by Prime PI?
    • If sub-award: Did Prime PI approve a request for NCE? (Exceptions — REU’s, Task orders and funds awarded internally and others – agency approval may be required for a technical justification)

Most sponsors allow grantee institutions to incur pre-award costs up to 90 days before the start date of a grant award.

If pre-award costs are not approved in the signed agreement, then agency approval is needed. The pre-award costs must be for the effective and economical conduct of the project and allowable on the project.

The request should contain the effective date of the request, a justification, and explanation of the type of change (payroll will require additional changes).

Questions referenced when PMR is reviewed:

  • What are the terms and conditions of the award?
  • Is agency approval needed?
  • What is the time frame for pre-award costs (60, 90, etc.)?
  • Detail justification (Why? When? etc.).
  • What type of cost? If a grad student, include that person’s name.

Note: Accounts that are originally set up as pre-award (K) are done so by requesting through RADAR. Once the official award document is awarded by SPARCS and assigned to FM, a review must be done to ensure that cost incurred did not take place before the official start date of the award document. A pre-award account (BA-148) is not the same as requesting pre-award costs (PAR). If NC State has expanded authority, you still need approval from C&G and SPARCS.

Equipment means tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost that equals $5,000 or more.

The purchase of capital equipment (equipment with a unit cost of $5000 or more) often requires prior approval by the sponsor if

  • The purchase of capital equipment was not included in the award budget, or
  • The PI or PO wishes to purchase a piece of capital equipment different from that included in the award budget.

Provide a generalized specification (cost, description) and justify the need for the equipment in relationship to the statement of work (why do you need the equipment).

Note: Equipment should not be purchased within the last three months of the project.

These requests must also be approved by the Department Head prior to routing to the Office of Contracts and Grants for review and processing.

Questions referenced when PMR is reviewed:

  • Technical reason why is it needed (purpose)?
  • How does it relate to the original scope of the project?
  • What equipment is needed? Is this from a different vendor than originally proposed?
  • Is it 100% for the project?
  • Cost? Is 100% of the cost being paid from this account or spread among different sources?
  • Do we retain title to the equipment?
  • What is the project end date?
  • Will the equipment be purchased, arrive and be used before the end date of the award?
  • Upload a quote for the amount.
  • Is agency approval needed?

Fabricated equipment is defined as an item of equipment that is built or assembled in its original form from individual parts by a PI and/or other sponsored project personnel, an internal shop, or an external shop.

If a fabricated equipment item will have an aggregate cost of less than $5,000, the individual costs for all acquisitions are subject to the relevant F&A rate. If you initially anticipate that the total fabrication will cost more than $5,000 and as such exempt the individual components from F&A but the final product ends up aggregating to less than $5,000 then all component costs will then be subject to F&A.

An instance where components are simply connected together in a system, such as when individual computers and servers are joined to create a network, does not constitute a fabrication.

Remember: If ownership of the final product is to transfer to the sponsor, the F&A rate applies to the individual fabrication components.

For fabricated equipment, be prepared to give the following:

  • Sponsor and award type (grant/contract)
  • Time frame for completing fabrication
  • Estimated dollar amount
  • Whether the item is a deliverable or not
  • Components and individual costs

Fabrications Notes:

  • Must be approved by C&G.
  • If approved then items under $5,000 can post to SSxxx, as long as they are
    not listed below as a “Never Capitalizable” item, and they are used in the
    final fabrication. Spare parts and repair parts cannot be included and
    would have to be moved back to the supply line.
  • Items simply wired together do not count as a Fabrication and will be
    reviewed individually.
  • Departments must notify the Capital Asset Group upon completion of a
    Fabrication, with a full listing of all charges included in the final fabrication
    for a final review, approval and capitalization (if warranted) of the
    fabrication into Asset Management.

Never Capitalizable:

  • Supplies, consumables, replacement/repair parts
  • Modular workstations and cubicle offices
  • Warranties
  • Maintenance contracts
  • Subscription services
  • Professional services (Not Installation, Training, or Shipping/Freight)

When a Fabricated Equipment request is approved and the Approval Email generated, it is the Fiscal Manager’s responsibility to update the Inventory Indicator attribute. The Fiscal Manager will change the attribute based on whether an inventory is required.

Primary Criteria for Capitalization: Per Asset Management Guidelines

Must qualify under each of the following criteria:

  1. Cost Threshold
    • $5,000.00 for a single piece of equipment (1 Computer, 1 Car, 1 RL Recorder)
      • Include additional cost for Shipping/Freight, Installation, & Training
    • $100,000 for a single Software License
  2. Life Expectancy
    • Two or more years of life (i.e., subscriptions, rentals, leases for less than one year — not capital)
  3. Physical Makeup of item
    • Singular Piece of Functional Equipment/Software
      • Computers, Monitors, Keyboards, Printers are all separate items
    • C&G Approved Fabrication
      • When parts are purchased in order to build a single piece of equipment. Ex. Capital Fabrication — Buy tires, an engine, a frame, some axles, etc., to build a car (the pieces used in the final car would be allowed to be capitalized as a Fabrication)
      • Ex. Non-Capital Fabrication — Buy three computers and a router, which are then wired together (this is not a Fabrication)

Subrecipients are entities that will contribute to the programmatic portion of the project. Their performance will be measured against whether the objectives of the project are being met. Subrecipients are subject to project compliance.

As the recipient of an award for a sponsored research project, the University may award financial assistance to a Subrecipient to facilitate performance of and payment for specific work to be conducted by the Subrecipient in connection with the sponsored project. A Subaward may be issued by the University as the recipient of a prime award or as the Subrecipient of another institution’s prime award.

Therefore, Subrecipients must adhere to the University’s awarded terms and conditions. Subrecipients should provide a detailed budget similar to NC State’s budgeted categories (i.e., salary, fringe benefits, travel, equipment, materials and supplies, consultants, indirect costs, etc.).  Please note if there is a sponsor restriction on F&A, direct costs, etc., then our Subrecipients must also adhere to said restriction in their budgets.

Subcontract Agreement:

  • It must be approved by the sponsor and include:
    • Current CV/Resume
    • Statement of Work
    • Budget Justification (new, supplement or de-obligation)
  • Budget/project dates must fall within the range of the direct sponsor.
  • Final reporting and billing are due 30 to 60 days prior to term date of direct sponsor.

Termination of Subawards: Upon termination of any Subaward issued from NC State to another institution, all financial, technical, property, patent and other required reports should be received from the Subrecipient along with a statement that it releases NC State from all further claims under the Subaward. The NC State PI should indicate that the Subaward was carried out in accordance with the work statement.

Questions referenced when PMR is reviewed:

  • Is subcontract request form completed/signed with CV, statement of work and budget attached?
  • Is subcontractor named/budgeted in the award?
  • Not named in award
    • Agency approval needed
    • CV, statement of work and budget needed
    • Justification (Why, purpose, expertise, etc.)
    • Is re-budget needed?
  • Amount requested is available in prime subcontract line.
  • Amount does not exceed budgeted amount for that subrecipient
  • Is this modification to subcontract?
  • What is changing in the subcontract?
  • De-obligation or increase in funding to sub-award?
  • If extending, be aware of the Prime end date. A sub-award/subcontract cannot extend past the Prime end date. Also, you may not want the sub with to have the same end date as the prime for turn-around times on final reports

The Budget is the financial expression of the project or program as approved during the award process. It is not uncommon for a PI to determine that for efficient performance of the project, he/she must re-budget funds from one budget line or category to another.

Some sponsors have delegated this authority to the University to approve these type of changes or modifications.

Some sponsors require the University to formally submit a budget modification with an explanation of the need and the anticipated impact, if any, on the conduct of the work.

The justification should describe:

  • How the proposed budget modification will affect the technical purpose or scope of the project;
  • Contain a brief explanation of why the proposed budget modification was not planned originally; and
  • Why other budgeted funds are now available for this purpose and the intended use of the funds.

A Budget Modification request may be submitted to realign the funds within specific budget categories. This type of modification may require agency approval.

A Budget Modification request may be submitted to move funds within Project Segments. Funds may only be moved to projects mapping to the Same Project Reference.

Questions referenced when PMR is reviewed:

  • What is the project term date? Note: C&G does not process re-budgets after the term of an award.
  • Is agency approval needed?
  • Is it an allowable budget line (i.e. student aid, equipment, etc.)
  • Will the scope of the project be changed?
  • Is a detail justification provided for each line item change (technical)?
  • Is object/Account Code correct – use approved account code list for your College.
  • Are there enough funds in the budget line to be moved?
  • Is F&A being affected? Has it been calculated correctly?
  • Will the subcontract line be affected? See sub-award request/modification.
  • Is this request for a segment? Was prime PI’s approval received and attached?

Sponsors award funding with the expectation that the named investigator will be responsible for directing or overseeing the project. If the investigator’s involvement is reduced or is not available for any reason, immediate notification to the sponsor is needed. The University may request a change in PI on a grant for any of the following reasons:

  • The PI transfers to industry or to another institution and is ineligible to continue the project.
  • The university the PI is transferring to is ineligible to receive funds.
  • Untimely death, serious illness or injury renders the PI unable to continue work on the project.
  • Change in the percentage of effort available by the PI to work on the project.
  • Change of circumstances that require the PI’s continued absence from the university or project for more than three months (e.g., sabbatical or military leave).
  • Other circumstances that, in the opinion of the University, necessitate a change in PI.

A detailed justification must be provided explaining how the change will affect the overall project, effective date of the change, purpose of the change and qualification of the new PI (CV/Vita).

These requests must also be approved by the Department Head prior to routing to the SPARCS Office for review and processing.

Questions referenced when PMR is reviewed:

  • CV/resume of New PI?
  • Why is the PI leaving or being added?  Note: NSF will only allow up to five PIs listed on a project.
  • What effect will this change have on the scope of the project?
  • The effective date of the change?
  • Will agency approval be needed?

Some sponsors restrict the amount of funds that may be automatically carried forward to the next budget period. If all funds are not spent by the end of a budget period, the PI may wish to use the unobligated balance or remaining funds in the next budget period. In such cases, the PI must request the carry-forward in writing, countersigned by SPARCS, and explain why there are funds remaining at the end of the budget period and how the funds will be used in the next budget period.

Questions referenced when PMR is reviewed:

  • Is carryover allowable by the sponsor?
  • Is agency approval needed?
  • Was a close out sent and returned?
  • What is the amount to be carried over?

Sponsors award funding with the concept that the proposed scope of work will be fulfilled with the approved funds.

In general, the Principal Investigator {PI) may make changes in the methodology, approach, or other aspects of the project objectives. However, the grantee must obtain prior approval from sponsoring agency for changes in scope, direction, type of training or other areas that constitute a significant change from the aims, objectives or purposes of the approved project. The grantee must make the initial determination of the significance of a change and should consult with the College Research Office (CRO) as necessary.

The PI or sponsor may request a formal change in scope, an explanation for the revised statement of work and budget, purpose of the change, any change in PI’s effort and if supplemental funding will be needed.

Note: After a grant or contract has been awarded, the PI or sponsor may determine that the approved scope is not consistent with actual needs or direction the project.

Questions referenced when PMR is reviewed:

  • Is a revised statement of work attached to budget?
  • The purpose for change in scope?
  • Will PI effort be affected?

Questions referenced when PMR is reviewed:

  • What is the purpose of the de-obligation (justification)?
  • The amount of de-obligation and why?
  • Will scope of the project be changed?
  • Will PI effort decrease?
  • Will the project period change?

The “Other” template should only be used when the request you need to submit does not fit within one of the other ten (10) request types.

Listed below are some examples of the type of requests that should be submitted under “Other”:

  1. Change in the percentage of effort available by the PI to work on the project. This change in percentage only and does NOT include a Change in Pl.
  2. Change of circumstances that require the PI’s continued absence from the University or project for more than three months (e.g., sabbatical or military leave). This does NOT include a Change in PI
  3. De-obligation (non-subawards)
    • A sponsor or PI may decide at any time to decrease the level of funding for an active project for various reasons (early termination, stop work, cut in funding, etc.).
    • A detailed justification explaining the purpose, amount, change in scope, PI effort and period change will need to be documented and approved
  4. Outgoing PI Transfer
    • When a faculty member transfers to another institution and has received permission from his/her department and college to transfer the project.
    • Upon receipt of the necessary departmental and college approvals, contact Debbie Shoe, COl Protocol Manager to begin the initial phase of the transfer
    • When instructed by Debbie Shoe, COl Protocol Manager to submit a PMR
    • Include a justification, effective date, and where the PI is going. PMR Request Approval
  5. Prior to routing request to C&G, it is the responsibility of the GBO to Adhoc in Prior Approval Coordinator – Kathi McFadden (KSMCFADD) and Assistant Director, Operations – Stefanie Saunders (SDSAUND2} as a Reviewer after C&G and then COl
  6. Early Termination
    • In certain instances, a project may terminate prior to the original expiration date, due to:
      • Accelerated rate of spending exhausts sponsored funds.
      • PI leaves the institution and the project will not be transferred or assigned a new PI.
      • Sponsor’s level of funding is reduced.
      • Sponsor requests termination.
      • Sponsor sends a Stop Work Order or Notice of Suspension.(See instructions in the Stop Work Order section.)
    • Award agreements typically include a clause for how an early termination situation will be handled. Generally, such notices would be sent by the sponsor to SPARCS, who should contact the Grant Business Officer (GBO} immediately.
    • If the notice is sent directly to the PI, a copy should be forwarded to SPARCS immediately. SPARCS will work with the GBO to evaluate the notice and plan a formal response to the sponsor.
    • Important: In the event of early termination, all required reports, such as financial, technical, and patents, must still be provided to the sponsor.
    • A PMR should be submitted with the dates for the termination, the unobligated balance and a justification for the early termination.
  7. Stop Work Order is a formal notice to cease or hold work on a contract. If not followed by an order to resume work, it amounts to the termination of the contract.
    • Stop-work orders may be used, when appropriate, in any negotiated fixed-price or cost-reimbursement supply, research, and development, or service contract if work stoppage may be required for reasons such as advancement in the state-of-the-art, production or engineering breakthroughs, or realignment of programs.
    • Generally, a stop-work order will be issued only if it is advisable to suspend work pending a decision by the Government and a supplemental agreement providing for the suspension is not feasible. Stop-work orders shall not be used in place of a termination notice after a decision to terminate has been made.
    • Stop-work orders should include
      • A description of the work to be suspended;
      • Instructions concerning the contractor’s issuance of further orders for materials or services;
      • Guidance to the contractor on action to be taken on any subawards; and
      • Other suggestions to the contractor for minimizing costs.
    • Promptly after issuing the stop-work order, the contracting officer should discuss the stop-work order with the contractor and modify the order, if necessary, in light of the discussion.
    • As soon as feasible after a stop-work order is issued, but before its expiration, the contracting officer shall take appropriate action to
      • Terminate the contract;
      • Cancel the stop-work order (any cancellation of a stop-work order shall be subject to the same approvals as were required for its issuance); or
      • Extend the period of the stop-work order if it is necessary and if the contractor agrees (any extension of the stop-work order shall be by a supplemental agreement).
    • PMR Processing:
      • For a PI-initiated Stop Work Order, a justification should indicate the purpose of the request and official date to stop work.
      • For agency-imposed Stop Work Order, a copy of the letter from the agency must be sent to sps@ncsu.edu to begin processing the Stop Work Order.
      • C&G will process the Stop Work Order upon receipt of the Award Notice from SPARCS.
    • Research Experiences for Undergraduates (REU) is awarded from a sponsoring agency for a specific student.
      • A change in personnel and a realignment of budget categories should be processed as PMR Type Other.
    • Participant Support Cost (PSC} requires written prior approval from the agency to reallocate funds provided for PSC.
      • A request should be processed as PMR Type Other.