University Corporation for Atmospheric Research

Finance & Administration

Program Change and Reprogramming Guideline

I. General Comments

This guideline is designed to assist divisions and programs in understanding when contractual authority is required to implement a program change or reprogram funds; and when there is a reprogramming limit set in the terms and conditions of an award, what should be done if a division or program has plans to or exceeds the reprogramming limit.

II. Definitions

A. Program Change – Program Change is defined as a change in the scope or the objective of a project or a program (even if there is no associated budget revision).

B. Reprogramming - Reprogramming is defined as a deviation from a sponsor -approved budget, which has been incorporated by reference into and becomes enforceable under an award. Recipients may be required to report deviations from an officially approved budget and request prior approvals for budget deviations, in accordance with an awards terms and conditions.

III. Program Change and Reprogramming Guidelines

Federally Issued Grants and Cooperative Agreements:

A. Individual awards may have their own reprogramming limits or restrictions, in addition to restrictions outlined in OMB Circular A110. If multiple reprogramming references are included in an award, contact the Sponsored Agreements Office for assistance in determining which restriction takes precedence.

B. It may be required that recipients obtain prior approval from a sponsor's contracting official when a program change or other budget related change occurs. Examples that generally require prior approval include:

•  Change in the scope or the objective of the project or program (even if there is no associated budget revision requiring prior written approval).

•  Change in a key person specified in the application or award document, e.g. principal investigator or co-investigator.

•  The absence for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.

•  The need for additional Federal funding.

•  The transfer of amounts budgeted for indirect costs to absorb increases in direct costs, or vice versa.

•  The inclusion, unless waived by the Federal awarding agency, of costs that require prior approval in accordance with OMB Circular A-122, "Cost Principles for Non-Profit Organizations," or 45 CFR part 74 Appendix E, "Principles for Determining Costs Applicable to Research and Development under Grants and Contracts with Hospitals," or 48 CFR part 31, "Contract Cost Principles and Procedures," as applicable.

•  The transfer of funds allotted for training allowances (direct payment to trainees) to other categories of expense.

•  Unless described in the application and funded in the approved awards, the subaward, transfer or contracting out of any work under an award. This provision does not apply to the purchase of supplies, material, equipment or general support services.

C. OMB Circular A-110 Reprogramming and Reprogramming Limit

•  When an award references OMB Circular A-110, UCAR is required to comply with Paragraph 25, Revision of Budget and Program Plans; and, UCAR will be required to report deviations from budget and program plans, as described in “B” above.

•  The reprogramming limit stated in OMB circular A-110 subpart c section .25 (f) applies to all awards which incorporate OMB Circular A-110 and have a total award value of $100,000 or greater. The reprogramming limit of 10% is calculated as the sum of the absolute value of all differences between the approved budget and actual expenditures. (See IV C. for example of calculation.)

Federally issued Contracts follow Federal Acquisition Regulations (FAR):

Reprogramming is dependent on contract type and the specific terms and conditions incorporated into the contract.

Reprogramming Restrictions for Other Commercially Issued Awards:

Reprogramming is dependent on award type and upon the specific terms and conditions incorporated into the award.

IV. Procedures

A. Roles and Responsibilities Concerning Reprogramming:

The division administrator and principal investigator are ultimately responsible for monthly monitoring reprogramming limits as part of compliance with the terms and conditions of each award. Project Accounting supports the efforts of the division administrator and principal investigator by alerting the division or program when an award appears to have exceeded or may exceed the reprogramming limit. Sponsored Agreements is responsible for determining whether a reprogramming limit applies to the award and to make the official request to sponsors for reprogramming approval per the division or program's request.

B. Requesting Reprogramming From A Sponsor:

It is at the division or program's discretion on how to deal with the reprogramming in their awards. If the division or program chooses not to request reprogramming authorities, UCAR management may step in and make the decision on what should be done to rectify the situation. If it is determined by either the division or program or UCAR management that reprogramming authority or approval is required, the division or program will need to prepare a new budget for the award and provide an explanation as to why the reprogramming is needed. Sponsored Agreements will review the request and work with the division or program if changes are needed. Once the reprogramming request is final, Sponsored Agreements will submit the request to the sponsor. Reprogramming authority can take as much as a year to receive from an awarding agency. Reprogramming requests should be submitted to the Sponsored Agreements Office for processing as soon as the division administrator or principal investigator know their spending will fall outside of the approved contractual limits.

C. Calculating the Reprogramming Limit - Sample

Grant A was awarded for $200,000 for a two-year period. Fifteen months into the effort, the program or division estimates that its planned expenditures through the end of the agreement will cause them to exceed the reprogramming limitation of 10% incorporated into the Grant. To help determine whether reprogramming authority or approval may have to be requested, the following calculation should be prepared by the division or program administrator:

Issued February 12, 2004