Prior approval is one of those quiet compliance rules that only becomes loud when it is missed. This article covers when written approval is needed, how to request it, and how to save the response for future reviews.
You are moving quickly on an active award when a good idea comes up. Maybe you want to shift some budget, purchase equipment, or add a subaward that was not part of the original plan. The work makes sense, the timing is right, and it can be tempting to move ahead and document the decision later.
That is where prior approval matters. Some grant actions require the agency's written approval before you act. If that step is missed, the related cost may become unallowable, and an otherwise strong grant file can have a serious gap.
The good news is that prior approval is a manageable process. Once you know which actions may require approval and where to find your award specific rules, the process often comes down to a clear email and a properly saved response.
Prior approval means you need written permission from the awarding agency before taking a particular action or charging a particular cost. The Uniform Guidance addresses prior approval in 2 CFR 200.407, which identifies situations where written approval may be required.
Federal awards are agreements built around an approved scope of work and budget. When you want to make a meaningful change to that plan, the agency needs an opportunity to review it before the change occurs.
Think of prior approval as a checkpoint. The issue is usually not whether the request will be approved. The greater risk comes from acting first and asking later.
The exact requirements depend on your agency, program, notice of award, and other award terms. However, these actions commonly require a closer look:
- A change in the scope or objective of the project
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A change involving key personnel named in the application
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Certain budget revisions, including transfers between direct and indirect costs
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Adding a subaward that was not included in the approved application
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Carrying unobligated funds into a later budget period
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Certain equipment purchases, travel expenses, or participant support cost changes
Some agencies grant expanded authorities that allow recipients to make certain changes without written approval. Your award terms may also add requirements or waive parts of the general rule.
The goal is not to memorize every agency's requirements. Instead, learn to recognize when a proposed action falls into one of these categories, then check the rules before proceeding.
The general framework is in 2 CFR 200, but the rules that apply to your award are found in your own grant documents. Start with the notice of award and any attached terms and conditions. Then review your agency's implementation of the Uniform Guidance and any program specific guidance for the funding opportunity.
Pay close attention to:
- Prior approval conditions listed in the notice of award
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Agency additions or waivers related to 2 CFR 200
- Expanded authorities for budget changes or no cost extensions
- Any thresholds that apply to specific costs or actions
When a new award begins, create a short prior approval summary and keep it with the grant file. That small step can save time when a decision comes up during a busy project period.
The request itself is usually simple. It should be in writing, sent to the correct official, and specific about what you want to do.
Send the request to the person identified in your award documents. This may be a grants management specialist, a program officer, or both. Explain the proposed action, why it supports the approved project objectives, and how it will affect the budget.
Your request should:
- State exactly what you are asking to do
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Include the dollar amount when relevant
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Explain how the action supports the funded work
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Identify any effect on the approved budget or timeline
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Request a written response
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Be saved with the agency's reply
A verbal approval can create confusion later. If a program officer agrees during a phone call, follow up with an email that summarizes the discussion and requests written confirmation. Save the response with the award records.
An approval you cannot find may be treated almost like an approval you never received. During a review, auditors and monitors may want to see the request, the written response, and the transaction connected to it.
Keep the full email thread and any supporting documents together in the grant file. Use a clear file name that identifies the action and date. If the approval relates to a purchase or budget revision, add the approval reference to the related transaction or budget entry.
Keep in mind that the person reviewing the file years from now may not be the person who requested the approval. A clear paper trail allows someone else to understand what was approved and why.
Prior approval is a matter of pausing at the right time and putting the answer in writing. When you know the common triggers and keep a short summary with each award, the process becomes easier to manage. A brief request and a saved response can protect the allowability of the cost and give your team a clear record for future reviews.
MyFedTrainer offers free resources to help you organize grant files and build practical compliance habits. Take a look when it is useful to you. 
