Updated: June 26, 2020


Sponsor flexibilities for waivers of prior approval requirements due to COVID-19 were based on OMB Memo 20-17. Those flexibilities were effective from March 16 - June 16, 2020. After June 16, 2020, those flexibilities have been rescinded by OMB Memo 20-26.

Please refer to the terms and conditions of your Award/Sponsor for requirements on expenditures or actions that require written Sponsor approval.

In its effort to provide administrative relief under COVID-19, the Federal Office of Management and Budget (OMB) has issued a memo that allows individual Federal Agencies to waive Prior Approval Requirements:

Awarding agencies are authorized to waive prior approval requirements as necessary to effectively address the response. All costs charged to Federal awards must be consistent with Federal cost policy guidelines and the terms of the award, except where specified in this memorandum (2 CFR 200.407).

If your Award’s sponsoring Federal Agency has waived any Prior Approval Requirements, the Agency will issue a notice or other communication to Award recipients. Check your Sponsor’s website to determine if they have issued such notifications. The Council on Governmental Relations (COGR) has also created a helpful website that tracks Federal Agencies’ responses to COVID-19.

If your Federal Sponsor has issued a modification to Prior Approval Requirements due to COVID-19, you can follow the modified requirements.  

If your Federal Sponsor has not issued any modifications, then there is no change to the Prior Approval Requirements issued on the Award.