Prior approval means the advance written approval of a specific cost or action to a particular federal award, by an authorized official of the sponsoring entity. Written approval must be in the form of a letter/memo provided as an email attachment or hard-copy from the authorized official; verbal approval during a telephone or in-person conversation is not sufficient. For Federal awards, the authorized official is typically a Grants Management Officer (GMO) assigned to the award.

Prior Approval Requirements

The Uniform Guidance (UG), contains many of the same prior approval requirements included previously in OMB Circulars A-110 and A-133. UG § 200.407 contains a complete list of items related to seeking prior approval by the Federal agency.

Many federal agencies have waived certain cost-related and other prior approval requirements for many activities and expenditures, and provided authority for these activities and expenditures to the grantee institution (previously referred to as "expanded authorities" under OMB Circulars). However, such waivers may not apply to certain awards as dictated by the sponsoring agency:

  • Certain award instruments, mechanisms, and types of recipients.
  • Certain grants or grantees, including those that require close project monitoring or technical assistance, or certain large multi-project grants.
  • Certain awards with particular terms and conditions.

Please review the award terms and conditions to determine to what extent prior approval requirements and waivers are applicable. If an award is excluded from some or all waivers, the award notice will indicate any change from the standard terms and conditions.