Organizational Prior Approval System (OPAS)

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Funding agencies have delegated 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 has established the Organizational Prior Approval System (OPAS).

The office of the Controller and Manager of Finance administer all external funding that comes to Middlebury according to applicable federal regulations, Middlebury policies, and the sponsor's particular award provisions and conditions. Authorized Organizational Representatives who are authorized to sign applications for external funding on behalf of the college include the Treasurer, the Controller, Manager of Finance, all members of the Office of Grants & Sponsored Programs, and the Director of Foundation Relations and Institutional Grants. 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 sponsored projects.  These procedures are provided to each Principal Investigator when an award account is established.

As Principal Investigator or Project Director, you are authorized to make charges to your award that are consistent with the sponsor-approved budget; however, adequate institutional reviews and approvals must be documented. 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 the federal cost principles applicable to the award
  • are consistent with the terms and conditions of the award and with sponsor and Middlebury 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  OGSP. for review. OGSP staff will sign it and 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 award period, incurring costs prior to the beginning of an award, or budget revisions that involve transferring funds among budget categories.

If the awarding agency has authorized Middlebury to approve such changes, the Manager of Finance will approve the request if the four conditions above are met. If Middlebury does not have the authority to approve the request, we 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.