Organizational Prior Approval System (OPAS)
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Funding agencies have delegated increasingly expanded authority to institutions to approve certain administrative actions. These agencies require grantees to assure that adequate institutional reviews and approvals are in place for decisions that affect the management of federally supported projects. All approvals must be documented. To provide these assurances, Middlebury College has established the Organizational Prior Approval System.
The Controller's office administers all external funding that comes to Middlebury College according to OMB Circular A-21, applicable federal regulations, Middlebury College policies, and the sponsor's particular grant provisions and conditions. Authorized Institutional Officials include the Treasurer, the Assistant Treasurer & Controller, and the Assistant Controller, who is authorized to sign all research grant applications on behalf of the college. The Grants Accounting Office has day-to-day responsibilities for accounting related to sponsored activities.
Middlebury College has developed Post Award Procedures to guide faculty and staff who administer grants. These procedures are provided to each Principal Investigator when a grant account is established.
As Principal Investigator or Project Director, you are authorized to make charges to your grant that agree with with the approved budget. Before incurring any charges that deviate from the awarded budget, you must consult the Grants Accounting Office, who will approve expenditures if they:
- are allowable under Circular A-21
- are consistent with the terms and conditions of the award and with sponsor and Middlebury College policies
- do not constitute a change in project scope
- are reasonable, necessary and allocable to the project
To request administrative changes, submit an OPAS Form to the Coordinator of Sponsored Research, who must review and sign it and will obtain any additional required signatures. Some examples of changes that require an OPAS form: expenditures or other actions that require prior agency approval, no-cost extensions of the grant period, incurring costs prior to the beginning of an award, or budget revisions that involve transferring funds among budget categories.
If the granting agency has authorized the College to approve such changes, the Assistant Controller will approve the request if the four conditions above are met. If the College does not have the authority to approve the request, the Assistant Controller will forward the request to the funding agency.
The signed OPAS Form is retained in the grant file for three years following submission of the final financial report.