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Prior Approvals for Non-Construction Grants & Cooperative Agreements: Federal Awards

07/25/2006 (Revised 12/26/2014)
Lorrie Lau
HQs Planning Memos and Guidance, Federal Highway Administration,

Budgetary Changes

  1. Additional funds. Increase in federal funds in grant. [2CFR200.308(b)]
  2. Rebudgeting. Cumulative transfers over 10% of the total budget among direct cost categories or among programs, functions or activities, and when the federal share exceeds Simplified Acquisition Threshold ($150,000). [2CFR200.308(e)] (No requirement for prior approval for budget revisions in grants less than $150,000.)
  3. Participant support costs. Transfer of funds allotted for conference participation, or training allowances to other categories of expense (i.e., from direct payments to trainees to other expense categories). [2CFR200.308(c)(5)]
  4. Carryover. Carry forward unobligated balances to subsequent periods of performance-Federal awarding agency may waive prior approval, at their option. [2CFR200.308(d)(3)]
  5. Liquidation of obligations. Liquidation of all obligations more than 90 days after the end of the period of performance. [2CFR200.343(b)]

Programmatic Changes

  1. Change in scope. Change in scope or objectives of grant supported activities. [2CFR200.308(c)(1)]
  2. No-cost extension. The need to initiate a one-time extension for period of performance by up to 12 months. Supporting documentation and revised period of performance must notify the Federal awarding agency. [2CFR200.308(d)(2)]
  3. Change in key person. If the grant award specified a key person in the application or the Federal award, or the absence or disengagement by a key person or for the principal investigator in research. [2CFR200.308(c)(2) &(3)]
  4. Transferring work. Subawarding, contracting or otherwise transferring of any work. [2CFR200.308(c)(6)]


  1. Cost-sharing and matching. Changes in the amount of approved cost-sharing or matching. This provision does not apply to supplies, materials, equipment or general support service. [2CFR200.308(c)(7)]

Real Property

  1. Transfer of title. Transfer to a third party of title to real property acquired under a grant. [2CFR200.311(c)(3)]

Procurement - States are to use their own procurement procedures [2CFR200.317]. Subrecipients are to follow the state's procurement procedure [2CFR1201); and local and Indian tribal governments who are direct grantees must follow the general procurement standards. [2CFR200.318] The simplified acquisition threshold is currently $150,000.

  1. Non-competitive contracts. The procurements is to be awarded without competition or only bid or offer in response to a solicitation [2CFR200.324(b)(2)].
  2. "Brand-name" contracts. Procurements over the simplified acquisition threshold which specify a "brand-name" product. [2CFR200.324(b)(3)]
  3. Awards to other than the low bidder. Proposed contracts over the simplified acquisition threshold to other than the apparent low bidder under a sealed bid procurement [2CFR200.324(b)(4)]
  4. Contract modifications. A proposed contract modification changing the scope of a contract or increasing the contract amount by more than the simplified acquisition threshold. [2CFR200.324(b)(5)]

Program Income

  1. Addition or matching use of income. Use of program income to meet cost sharing or matching requirements or to add to the funds already committed to the grant. [2CFR200.307(e)(3)]

Other Actions

  1. Information collection. Collection of information from others if they are told that the information is being collected for or on behalf of the Federal grantor agency. [5CFR Part 1350, Controlling the Paperwork Burden on the Public]
  2. Reporting. Any change in the prescribed frequency or due date of reports. [2CFR200.328(b)(1)]
  3. Restrictions in the grant award. Using funds for any purpose or type of cost that was expressly disapproved as a condition of the grant. [implicit in all grants]

Allowable Costs [References are paragraphs in 2CFR200, Subpart E - Cost Principles]

  1. Advisory council (or committee) costs are unallowable direct cost, unless authorized by the Federal awarding agency or as an indirect cost. [200.422]
  2. Compensation -fringe benefits: Severance pay. [200.431(h)(6)(i)]
  3. Equipment and other capital expenditures. [200.439]
  4. Insurance on property owned by the federal government. [200.447]
  5. Uninsured losses (including property losses and liabilities to third parties) which could have been covered by permissible insurance (except nominal deductible amounts or other minor uninsured losses such as ordinary spoilage, breakage, etc.). [200.447(c)]
  6. Membership in civic and community, social organizations as a direct cost. [200.454(c)]
  7. Preaward costs. [200.458]
  8. Proposals costs as an indirect cost. [200.460]
  9. Rearrangements and alterations of facilities as a direct cost. [200.462(a)]
  10. Travel costs of general government officials (see 200.444). [200.474(a)]
Updated: 12/29/2014
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