Is Prior Approval Required to Change the Level of Effort for Key Personnel on a Grant Award?

Yes, the PD/PI and other Senior/key personnel named in the notice of award must devote a measurable level of effort to the project. If the level of effort is reduced by 25 percent or more from what was approved in the initial competing year award, prior approval from NIH would be required. (See NIH Grants Policy Statement Chapter 8.1.2.6). With the exception of grant programs that have an effort requirement, or where terms and conditions prohibit such reductions, NIH does not require prior approval for the reduction in effort for Senior/key personnel named in the notice of award during a no-cost extension.

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7 thoughts on “Is Prior Approval Required to Change the Level of Effort for Key Personnel on a Grant Award?

  1. Hi,
    In general, NIH has a cut of the budget and to fit in the new reduced budget, I try to keep the same efforts from the PI (me) but have to trim others including research staff and collaborators. In my recent funded R01 grant, I have 5 collaborators (also called as co-PIs). Are co-PIs considered as the “other Senior/Key personnel” so that prior approval is required to change the level of their efforts?
    Thanks,
    Charlie

    • Hi Charlie,

      Only if those individuals are also named on the notice of award (typically either they serve as MPIs or, alternatively, are called out under Sec. IV, Special Terms).

      See NIH Grants Policy:

      Change in status of the PD/PI or senior/key personnel named in the NoA (8.1.2.6)

      Examples:

      Withdrawal from the project; absence for any continuous period of 3 months or more; reduction of the level of effort devoted to project by 25 percent or more from what was approved in the initial competing year award.

  2. Can you clarify “PD/PI and other Senior/key personnel named in the notice of award”? On the NOA, only the PD/PI is listed. Co-PIs are not listed. Does that mean we do not need prior approval on their status?

  3. I have a question about the 25% reduction rule.

    Below is the excerpt from the NIH website.

    Is Prior Approval Required to Change the Level of Effort for Key Personnel on a Grant Award?

    Yes, the PD/PI and other Senior/key personnel named in the notice of award must devote a measurable level of effort to the project. If the level of effort is reduced by 25 percent or more from what was approved in the initial competing year award, prior approval from NIH would be required. (See NIH Grants Policy Statement Chapter 8.1.2.6). With the exception of grant programs that have an effort requirement, or where terms and conditions prohibit such reductions, NIH does not require prior approval for the reduction in effort for Senior/key personnel named in the notice of award during a no-cost extension.

    The rule states that if the PD/PI and other Senior/key personnel named in the notice of award reduce their effort by 25% or more, prior approval from NIH would be required.
    To determine level of effort, do we take the average FTE over the current year and compare it with what was approved in the initial competing award? For example, for the PD/PI, their FTE averages 15% over the current period which is year 3 of the grant. On the initial submission of the budget proposal that was approved by NIH, we budgeted 20% FTE for the PD/PI for year 3. Does that mean we would have to get NIH approval since, the average FTE is more than 25% less than what was originally budgeted?

    Also, are subcontract-PI’s considered to be other Senior/key personnel for purposes of the 25% reduction rule? For example, our PD/PI is a sub-contractor to Boston University which is the flow through sponsor to NIH. Our PD/PI is considered to be key personnel by Boston University, however on the parent notice of award from NIH, our PD/PI’s name is not specifically mentioned in the parent notice of award. Does this mean that our PD/PI is exempt from the 25% reduction rule?

    Also, just for clarification, if a Principal Investigator, who has a direct notice of award with NIH, even if they are not specifically mentioned in the notice of award, they are still subject to the 25% reduction rule.

    Another point I need clarification is that, only when a co-investigator or other senior key/personnel who are a sub-contractor to a flow through sponsor who are specifically named in the flow through sponsor’s parent notice of award, that personnel would be subject to the 25% rule. If the parent notice of award is silent on who is considered senior key/personnel, then those key personnel of the subcontract are not subject to the 25% rule.

    • According to Section 8.2.1.6 of the GPS, the reduction of time devoted to the project is determined by comparing the current (and cumulative change) effort to that approved at the time of initial competing year award. For example, a proposed change from 40 percent effort to 30 percent or less effort or in calendar months a change from 4.8 to 3.6 calendar months). Reductions are cumulative, i.e., the 25% threshold may be reached by two or more successive reductions that total 25% or more.

      So, to address your first set of questions, since the average of the actual FTE over the first 3 years of the award is more than 25% less than what was originally budgeted, yes you would have to get NIH approval.

      As to your second group of questions, the requirement for NIH prior approval applies to key personnel identified in the NIH notice of award (in this case the “prime” award.) The NIH Grants Policy Statement (Sec. 15.2.4 on Approval Authorities for Consortium Grants) is silent on whether the prime/pass-through recipient must flow down prior approval waivers that the NIH awarding Institute/Center has provided to the prime. It only prohibits the prime from waiving prior approvals to the sub that NIH has not provided to the prime. If the prime/pass-through recipient includes such a prior approval requirement on its notice of award to the consortium partner, then prior approval from the prime/pass-through organization would be required before such a reduction in effort.

      And as to your final set of questions, see answer above. If the pass-through entities notice of award is also silent on the senior key personnel at the consortium subawardee institution, we recommend contacting an official sponsoring office at the prime organization for guidance in clarifying the situation.

      If you have additional questions we recommend consulting our searchable FAQ database: https://grants.nih.gov/grants/frequent_questions.htm If you cannot find your answer there, we recommend contacting NIH directly via email, or through the contact form on grants.nih.gov.

  4. If you propose, for example, 12 calendar months at 10% (1.2 cm) for the PI, but NIH only awarded 6 calendar months due to, for example, a recycling of the award, can the PI cut his effort without prior approval for the reduction in time to 6 calendar months at 10% (0.6 cm) because of the reduction of time for the first budget period?

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