GAP 200.160, Rebudgeting Funds on Sponsored Projects

Contents

1. Purpose
2. Sponsor Approval
3. Internal Process
4. Federal Regulations

I. Purpose

The Sponsor expects that applicants will anticipate the entire cost of the project in the proposal and incur costs according to the budget categories in the proposal. However, during the life of the project, PIs may determine they need to depart from the approved budget; therefore, some sponsors permit awardee institutions to depart from the approved budget as long as the project funds are used in compliance with their policies and regulations. This procedure gives the general guidelines for rebudgeting funds on sponsored projects. Each award document and the corresponding sponsor guidelines should be reviewed carefully for specific sponsor restrictions and regulations.

II. Sponsor Approval

While each Sponsor varies in the degree of rebudgeting authority granted to institutions, most awards require the sponsor’s prior written approval of a rebudgeting of funds when any of the following would result:

• Any activity restricted as a condition of the award
• A change in scope, objectives, or purposes of the approved project.
• A decrease in the total amount budgeted for training costs.
• Any rebudgeting of funds in or out of patient care costs; also, any addition of patient care costs if no patient care costs were in the approved budget.

If any clarification on rebudgeting is needed, contact the Office of Research Administration (ORA) or Office of Research Support (ORS), who will involve Post Award Financial Management or Office of Post Award Administration, as necessary.

If the rebudgeting requires the approval of the sponsor, Duke must submit a request to the sponsor for prior approval. The owning org should draft the request, including PI approval, and send it to ORA or ORS for approval and submission by an authorized organizational representative of Duke University. The request must include:

1. A justification for the change, as it relates to the scientific or programmatic aims of the project;
2. The specific amounts in each budget category to be increased and decreased;
3. The sponsor’s project identification information, such as award number or title;
4. The affected budget period(s).

III. Internal Process

Once sponsor approval of the rebudgeting is obtained, or if it does not require sponsor prior approval, then the owning org must complete a Rebudgeting/CAS Form in the Duke@Work portal. Please refer to the Rebudgeting/CAS Step-by-Step Guide for further details.

A completed Rebudgeting/CAS Form includes a justification (as it relates to the scientific or programmatic aims of the project), the specific amounts in each budget category to be increased and decreased, and if applicable, the sponsor’s approval documentation. The Rebudget/CAS Form provides the specific amounts to increase or decrease in budget categories so that central office personnel can correctly execute the rebudget in SAP.

If there is an impact on CAS personnel or non-personnel categories, separate justification must be provided to support the addition of these expenses. Please refer to GAP 200.360, Charging Clerical and/or Administrative Costs to Federally Funded Projects for details on CAS expenses.

Please note, rebudgeting may have an impact on the Facilities and Administrative (F&A) costs collected on a project, depending on which categories of costs are being increased and decreased. Departments should review any potential changes to F&A throughout the rebudget process and seek clarification from ORS or ORA if necessary.

IV. Federal Regulations

This GAP reflects the provisions of the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR Part 200, otherwise referred to as the Uniform Guidance (UG). The UG became effective as of December 26, 2014, and revised as of November 12, 2021, and all awards issued on or after this date must be managed in accordance with its provisions. It is important to verify the applicable regulations for an individual award, which may be found in the Award Notice issued by the funding agency.

These guidelines pertain to federally sponsored projects and should be used as guidance for all sponsors unless specifically addressed in a non-federal sponsor’s policies and/or procedures.

This GAP supersedes previous GAP versions, Duke Policies, Guidelines, etc.

Note: This guidance is administrative in nature and is not a cost reimbursement policy. Failure to comply may or may not result in adjustments of charges to the award. Noncompliance with this policy does not mean this cost is unallowable from an external perspective. Any adjustments of charges will be as required under applicable federal cost reimbursement principles. If a cost is removed from an award for any reason, whether or not related to this guidance, the cost will generally be charged to departmental funds.