Spotlight on Policy: Expanded Authority

By: Maggie Gallagher-Mondak

Today’s Spotlight provides a bit of useful information about Expanded Authority and its origins through the Federal Demonstration Partnership.

 

Expanded authority was conceived by the Federal Demonstration Partnership (FDP).  The FDP is a cooperative initiative among 10 federal agencies and 155 institutional recipients of federal funds.  The FDP’s purpose is to reduce the administrative burdens associated with research grants and contracts.  Note: VCU is a member of the FDP Phase VI!

 

Expanded Authority gives grantee institutions unilateral authority to:

  • Incur pre-award costs 90 calendar days prior to award. All pre-award costs are incurred at the recipient’s risk.
  • Initiate a one-time extension of the award expiration date of up to 12 months. The grantee must notify the Federal agency in writing with the supporting reasons and revised expiration date at least 10 days before the expiration date specified in the award!  This one-time no cost extension may not be exercised merely for the purpose of using unobligated balances.
  • Carry forward unobligated balances to subsequent funding periods.
  • Rebudget funds across budget categories (limited.

 

In practice, individual Federal agencies have implemented some or all of the Expanded Authorities for research grants.  For example, NIH’s implementation of Expanded Authorities for research grants is identical to its implementation of the FDP terms and conditions.  Always refer to the specific agency’s regulations and to the particular grant award notice for clarification of institutional authorities.

 

Federal Guidance

  • 2 CFR 200.308 Revision of Budget and Program Plans – section (d)
  • OMB Circular A-110 Section __.25(e) authorizes agencies to waive cost-related and administrative prior written approvals required by A-110 and A-21.

 

HRSA’s Expanded Authority Policy is available here:

http://www.hrsa.gov/grants/hhsgrantspolicy.pdf

 

A list of agencies and their expanded authorities is available from Tufts University here:

http://viceprovost.tufts.edu/researchadmin/manage-award/expanded-authority-actions/

  • Each participating Federal agency has its own Agency Specific FDP Terms & Conditions. These terms vary from the General Terms & Conditions.
  • ALWAYS be familiar with the Agency Specific FDP Terms for the granting agency with which you are working!

 

VCU’s Policy: Post Award Changes – Rebudgeting, Prior Approvals and University Expanded Authority Approval

 

Takeaway:  Read the terms of your federal award to know if Expanded Authority applies or not.  Remember that agencies update their Agency Specific FDP Terms &Conditions periodically.  The terms in effect at the time the award was issued, govern the award.

 

 

 

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