Summary 

This page clarifies and updates campus procedures for the submission of budgets exceeding $500K annually in direct costs to NIH for prior approval. 

Effective Date: August 20, 2021

Background 

  • Any applicant requesting $500,000 or more in direct costs (excluding consortium F&A costs) in any one budget period is required to contact the IC PO, in writing or by telephone, as early as possible during development of the application but no later than 6 weeks or as specified in the funding opportunity announcement before submission for prior approval.  

  • See the NIH Grants Policy Statement for additional information. 

Procedures 

  1. OPAS will review an advance budget before a PI submits a request to their Program Official for Prior Approval for a proposal requesting more than $500,000 direct costs in any given year. Such requests are initiated by the PI through the Prior Approval module in ERA Commons. Instructions and required documents vary among the different NIH Institutes and Centers. 
  2. The PI should create a pre-proposal record in Kuali including a draft narrative/scope of work, a detailed budget, budget justification, RFP, and any additional documents required by the NIH IC or Program Officer (data management plan, cover letter, etc.) for review.  The standard 5-day internal deadline policy will apply. Please note that the request is due to NIH a minimum of 6 weeks prior to the full proposal due date.
  3. The PI may submit the request independently without having OPAS review, with the understanding that changes may be necessary once the proposal is routed to and reviewed by OPAS. Budget totals may not be subject to change, but line items may be adjusted to ensure compliance with internal standards and policies (i.e., correct wages, fringe rates, F&A, tuition charges, etc.). If submitting independently, no Kuali record or interface with OPAS is required.
  4. If submitting independently without OPAS review, the PI should be aware they will cover any budget shortfall(s) to avoid exceeding the NIH-approved limits at proposal stage. Other options are a) to submit a revised request to the NIH as time allows, or b) wait until the next round if they can't make the cuts to other line items in this round.
  5. If UMass is a subrecipient, OPAS does not pre-review a budget for a $500K request, as the request is the lead institution's responsibility. The only exception is when the lead institution requests institutional approval from UMass Amherst prior to making the $500k+ request to NIH, in which case a pre-proposal Kuali record with a draft narrative/scope of work, a detailed budget, budget justification, RFP, and any other requested documents should be routed to OPAS for review and submission to the lead institution (please see item #2 above). The standard 5-day internal deadline policy will apply.