Federal grant budget changes: when you need prior approval

The rule and who decides

The baseline is 2 CFR 200.308. It requires a recipient or subrecipient to report deviations from the approved budget, scope or objectives, and to request prior approval for the revisions the section lists (200.308(b)). Prior approval means written approval obtained in advance from an authorized official of the federal agency or pass-through entity (2 CFR 200.1). An email from program staff may or may not meet that standard, so ask who is authorized to approve.

A recipient asks the awarding agency. A subrecipient asks the pass-through entity, which can only approve what the prime award lets it approve. Some changes still go up to the federal agency for a decision.

Start with the award or subaward terms and the awarding agency's or pass-through entity's current instructions. Those documents may impose program-specific or stricter requirements in addition to the Uniform Guidance. If the instructions appear to conflict, ask the awarding agency or pass-through entity for written clarification before acting.

The section also limits federal agencies. An agency "must not impose additional prior approval requirements without OMB approval," unless the guidance itself specifies them (200.308(e)). That limit is written for federal agencies. A pass-through entity may add its own requirements to a subaward (2 CFR 200.332(b)(3)), so a subrecipient can face approval steps that a direct recipient would not.

Changes that always need prior written approval

An agency may waive many cost-related and administrative approvals, but not these ten (200.308(f) and (g)):

The scope trigger is the one to test first. A different item, a new site, a new population served or a changed objective may be a scope change even when the dollars stay on the same line. If you are not sure, describe the change to the agency or pass-through entity in writing and ask whether it treats it as a scope change.

The cost-principle trigger in (f)(4) links this section to Subpart E. Equipment is a common example: general purpose equipment, special purpose equipment with a unit cost of $10,000 or more, and capital improvements need prior written approval (2 CFR 200.439(b)). 2 CFR 200.407 lists the other sections where approval decides allowability. Whether a cost is allowable at all is covered in the allowable costs guide.

Moving money between cost categories

A move between approved budget categories, such as from supplies to personnel, is not on the (f) list by itself. Under 200.308(i), the federal agency "may also, at its option," restrict such transfers, but only when both of these are true:

• The federal share of the award exceeds the simplified acquisition threshold, which FEMA reports rose to $350,000 on October 1, 2025 (Preparedness Grants Manual, section 6.5.2).
• The cumulative transfers exceed, or are expected to exceed, 10% of the total budget as last approved, including cost share.

Read that rule carefully. It does not give every recipient a 10% cushion, and it does not require approval at 10%. It sets the point at which an agency is allowed to impose a restriction, and the restriction itself appears in the award terms or the agency's guide. The transfer still has to fit the scope and be reported.

Agencies apply this differently. The Justice Department's Grants Financial Guide (last updated December 2025), for example, requires a grant adjustment notice when the proposed cumulative change is greater than 10% of the total award, says the 10% rule does not apply to an award of less than $250,000, and requires a notice for any change that affects a cost category not in the original budget. Other agencies use different procedures. A pass-through entity may require approval for any move.

More time: no-cost and one-time extensions

A no-cost extension adds time without adding federal money. The regulation recognizes two kinds (2 CFR 200.308(f)(10) and (g)(2)):

• A one-time extension of up to 12 months, which the recipient may start without prior approval if the award terms authorize it. The recipient must still notify the agency in writing, with a justification and a revised period of performance, at least 10 calendar days before the period ends. Prior approval is required if the terms prohibit the extension, if it needs more federal funds, or if it changes the approved scope.
• Any other no-cost extension, which needs prior written approval. Requests should go in at least 10 calendar days before the period ends. The agency may approve more than one if no statute or regulation prohibits it.

Ten days is the federal floor. Agencies and pass-through entities may set earlier deadlines; the Justice Department's guide, for example, asks for its extension request at least 30 calendar days before the end date (DOJ Grants Financial Guide, Part III). A subrecipient's own period may end before the prime award's, and its request goes to the pass-through entity on that entity's schedule.

Until an extension is approved or properly noticed, the existing end date controls. Costs for ordinary work must be incurred during the approved budget period (2 CFR 200.403(h)), and the final report and liquidation clocks run from the end of the period of performance (2 CFR 200.344(b)–(c)). The closeout guide covers those deadlines.

Approvals an agency may waive

Except for the ten items above, a federal agency may waive the cost-related and administrative prior approvals in Subparts D and E (200.308(g)). The regulation names three examples:

• Pre-award costs incurred up to 90 calendar days before the award date, at the recipient's own risk.
• The one-time extension described above.
• Carrying forward unobligated balances to later budget periods.

A waiver exists only if the award terms or the agency's regulations grant it. Check the terms before relying on one.

How to ask

1. Use the right format.A budget revision request must use the same budget format as the application, unless the agency has approved another format, such as an electronic system or email (200.308(c)).
2. Send it to the deciding party.A recipient sends it to the awarding agency. A subrecipient sends it to the pass-through entity, through the channel the subaward names.
3. Wait for the decision.The agency or pass-through entity must review the request and should tell you within 30 days whether it is approved. If review will take longer, it must tell you in writing when to expect a decision (200.308(d)).

A good request names the approved budget lines and amounts, the proposed change, the reason for it, and its effect on the objectives and the schedule. Ask for the decision and governing provision in writing, and keep the approval with the award records. Changes that need no approval must still be reported in the manner that 2 CFR 200.329 and the award terms require; that section also requires notice of problems or delays between reports (200.329(e)).

Spending first and asking later puts the cost at risk. A cost that needed prior approval and didn't get it can be disallowed when the agency or pass-through entity reviews the claim, the report or an audit.

A program example

Program guidance can narrow these rules further. For the Nonprofit Security Grant Program (NSGP), the State Administrative Agency forwards a subrecipient's scope change to FEMA, which decides it; budget-only moves follow FEMA's manual and the state's subaward. The NSGP budget and scope changes guide walks through that process. The federal grant compliance checklist shows where approvals fit in the life of any award.