**Post Award Administration -- Prior Approval**

**Note: Unless otherwise indicated, the excerpts below are from the HHS
Awarding Agency Grants Administration Manual (Hot Links Provided)**

**Authorities**

The Department of Health and Human Services (DHHS) policies provide the
recipients the maximum allowable flexibility to make post-award changes
in programmatic plans and budgets consistent with governing statutory,
regulatory, administrative, and policy requirements.

**Responsibilities**

Most prior-approval requests have both programmatic and business
implications, therefore the Grants Management Officer (GMO)/Grants
Management Specialist (GMS) and the Project Officer (PO) will evaluate
the request for their respective areas either programmatic or business
implications of a given activity.

The Grants Management Specialist (GMS) and the Project Officer (PO)
roles are defined roles, each of which must be appropriately performed
to ensure a compliant grant process and contribute to achievement of
program/project outcomes. These roles can be carried out in a
responsible manner only when there is effective interaction between the
GMS and PO.

Grants Management Officer is responsible for reviewing the request with
Project Officer, as necessary, and for informing the grantee in writing
of the final disposition of the request. Only responses signed by the
GMO are to be considered valid.

**Documents Impacting the Administration of Grants/Cooperative
Agreement**

Governing statute/program legislation -- Public Health Act

Program regulations -- Terms and Conditions of the Award

Grants Administration Regulation -- 45 CFR Part 74

Policy Requirements

-   HHS Grants Policy Directives **(CDC's Use Only)**
    [www.hhs.gov/grantsnet/](http://www.hhs.gov/grantsnet/)

-   HHS Grants Policy Statement (External for the Grantee) -
    [www.hhs.gov/grantsnet/](http://www.hhs.gov/grantsnet/)

-   HHS Awarding Agency Grants Administration Manual (AAGAM) (**CDC's
    Use Only)**
    [[http://intranet.hhs.gov/grantsinfo/gpdstable.html]{.underline}](http://intranet.hhs.gov/grantsinfo/gpdstable.html).

> **Post Award Administration -- Prior Approval**

Office of Management and Budget (OMB) - Educational Institutions (even
if part of a State or local government) follow:

-   [A-21](http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html) -
    High Institutions of Higher Education Cost Principles, [[Relocated
    to 2 CFR, Part
    220](http://www.whitehouse.gov/omb/fedreg/2005/083105_a21.pdf)]{.underline}

-   [A-110](http://www.whitehouse.gov/omb/circulars/a110/a110.html) -
    Grants and Cooperative Agreements to Institutions of High Education,
    Hospitals and other Non-profit Organizations - Administrative
    Requirements, [Relocated to 2 CFR, Part
    215](http://www.whitehouse.gov/omb/fedreg/2005/083105_debarment.pdf)

-   [A-122](http://www.whitehouse.gov/omb/circulars/a122/a122_2004.html)
    -- Non-profit Organizations under Federally-sponsored Agreements -
    Cost Principles, [Relocated to 2 CFR, Part
    230](http://www.whitehouse.gov/omb/fedreg/2005/083105_a122.pdf)

**Mandatory Receipt and Control Points**

-   PGO/GMS -- Official receipt and control point for all requests for
    prior approval.

-   PO -- Requests for prior approval are incorrectly or inadvertently
    receives (he/she should date and time stamp) and immediately
    forwarded them to responsible GMS.

    **Prior Approval Response Time**

    The CDC is required to respond to requests for prior approval within
    29 (based on CDC Key Performance Indicator (KPI) calendar days of
    receipt or advise the recipient when it can expect a response, but
    should try to respond as soon as possible and not use the full 29
    days (or longer) as a means of "disapproving" the request by
    allowing the request to be overtaken by events.

The 29-day response requirement will be calculated from receipt by the
CDC, whether the GMO or the PO receives the request. For requests other
than e-mail requests, receipt will be determined from the date of the
request, the postmark

> **Post Award Administration -- Prior Approval**

CDC Prior-Approval Not Required

Grantees are given a certain degree of flexibility in making post-award
programmatic and budget revisions on the basis of an approved
grant/cooperative agreement. Unless otherwise restricted by the terms of
the award, grantees have the flexible to re-budget within and between
budget categories in the approved total direct cost budget of the
project to meet unanticipated requirements or to accomplish certain
programmatic changes and using as a guideline, \*"significant
re-budgeting" threshold as long as the re-budgeting does not result in a
change in scope of the program.

\*"Significant re-budgeting" is a threshold that serves as a
quantitative indicator of a possible change in scope. Significant
re-budgeting occurs when, under a grant/cooperative agreement where the
Federal share exceeds \$100,000, cumulative transfers among direct cost
budget categories for the current budget period exceed 25 percent of the
total approved budget (inclusive of direct and indirect costs and
Federal funds and required matching or cost sharing) for that budget
period or \$250,000, whichever is less. For example, under a grant in
which the Federal share for a budget period is \$200,000, if the total
approved budget is \$300,000, cumulative changes within that budget
period exceeding \$75,000 would require prior approval).

**The sample letters are not an all inclusive list of the types of costs
and activities that require CDC prior approval.**