There are two main types of Approvals in Fiscal Compliance:
- Sponsor Approval, where documented sponsor approval is provided prior to a purchase or action.
- PI Approval, where – per UW’s GIM 2 – the PI or their designee must approve all expenditures and actions.
All approvals must be documented and that documentation retained in accordance with the UW Record Documentation Schedule.
Approvals can be for actions or expenditures. Examples include:
- No-cost extension
- New or unplanned award activity
- Change in Award Scope
- Increase or reduction in funding
- Increase or reduction in PI, or other Key Personnel, on the Award
- Pre-Award Expenditures
Sponsors will determine which expenditures or actions require their prior approval. A list of requirements can be found in the Award itself, the Award announcement or instructions, and/or the sponsor’s documented regulations.
If an expense or activity is clearly itemized in the proposal, budget and/or budget notes, and the sponsor provides funding that is equal to the proposal budget, then the UW considers that as sponsor approval. If the expense or activity is not included or is not itemized in the proposal, then approval is not considered to have been obtained even if the award is funded at the proposed budget level.
If Sponsor approval is required after an Award has been issued, the approval must be:
- From the person authorized by the Sponsor to provide such approval;
- In writing; and
- Retained on file for the duration of UW’s Record Retention Schedule.
Note: on Federal Awards, there is typically a Program Officer, who is responsible for the research, and a Grants Officer, who is responsible for expenditure and activity approvals. Not all Program Officers understand that they are not authorized to provide most approvals so be sure to review the Award and sponsor requirements to determine who is authorized to provide approvals.
Approvals must be obtained prior to the expenditure being incurred or the activity taking place. If the approval is retroactive, the sponsor should be told, as part of the request for approval, that the approval is retroactive.
Sponsors may waiver their prior approval requirements. This means that rather than approval being provided by the Sponsor, it must instead come from the PI. If the Sponsor has waived the approval, be sure that the PI’s approval is documented and retained on file.
Sponsor waivers can be provided in the Award, the Program Announcement or Sponsor Guidelines, or the Sponsor’s regulations. For Federal Sponsors, waivers may be provided in the Research Terms and Conditions.
Note: Some sponsors use the term “expanded authorities” to refer to approval waivers.
Per UW’s GIM 2, the PI is responsible for Award implementation. This means approval of all expenditures, administrative actions, and Award activities. GIM 2 provides for which of those approvals may be delegated by the PI to other individuals.
As with Sponsor approval, PI and designee approvals must be in writing and must be retained in accordance with UW’s Records Retention Schedule.