Federal Budget Revisions and Prior Approval

A budget being mathematically balanced does not make a revision authorized. For a Federal award, test the proposed operational change, the award terms, and the cost item—not only the dollars moved between rows. Obtain approval from the Federal agency or pass-through entity that has authority under the award.

This guide reflects the eCFR current on August 2, 2026. The signed award, program law and regulations, agency implementation, and incorporated terms may be stricter or more specific.

Every current § 200.308(f) trigger

2 CFR 200.308(f) requires the recipient or subrecipient to request prior written approval for all ten reasons below:

1. Scope or objective changes, even without an associated budget revision.
2. Changes in key personnel, including employees or contractors identified by name or position in the award.
3. Project director or principal investigator disengagement for more than three months, or a 25 percent reduction in that person's time and effort over the period of performance.
4. Including costs that require prior approval under subpart E, unless the Federal agency waived the applicable approval.
5. Moving participant-support funds to another budget category.
6. Subaward activities not proposed and approved in the application and award. A change of subrecipient requires prior approval only if the award terms require it; generally it should not be required unless the original subrecipient was material to merit review or eligibility. This trigger does not cover procurement transactions for goods and services.
7. Changing the total approved cost-sharing amount.
8. Needing additional Federal funds to complete the project.
9. Transferring funds between construction and non-construction work.
10. A no-cost extension, except a qualifying one-time extension authorized under § 200.308(g)(2). Requests should be submitted at least 10 calendar days before the period of performance ends. An agency may approve multiple extensions unless statute or regulation prohibits them.

Also report deviations from the approved budget, scope, or objectives as required by §§ 200.308(b) and 200.329. Approval and reporting are related controls, not substitutes for each other.

The one-time no-cost extension is conditional

Under § 200.308(g)(2), prior approval is unnecessary only if the award terms authorize the recipient to initiate one extension of up to 12 months. The recipient must still give the agency written notice, supporting justification, and the revised period of performance at least 10 calendar days before the end date.

Do not use this authority:

• solely to spend unobligated balances;
• when the award terms prohibit the extension;
• when additional Federal funds are needed; or
• when the extension changes approved scope.

Those last three circumstances require agency prior approval. Further extensions may be approved by the agency; they are not self-executing. Research awards receive the waivers described in § 200.308(h), but the paragraph (g)(2) exceptions still require approval. An extension changes time—not automatically scope, funding, cost allowability, or a subaward.

The “10 percent rule” is not universal permission

There is no universal rule that recipients may move up to 10 percent without approval. Under § 200.308(i), an agency may, at its option, restrict transfers among direct-cost categories or programs/functions/activities only when:

1. the Federal share exceeds the simplified acquisition threshold; and
2. the cumulative transfer exceeds or is expected to exceed 10 percent of the total budget, including cost share, as last approved by the agency.

This provision describes when an agency may impose that restriction. It does not override § 200.308(f), an award-specific restriction, scope, appropriation limits, or cost allowability. Calculate any applicable threshold cumulatively against the last agency-approved total budget; do not reset it for each journal entry.

Cost-item approval is a separate test

2 CFR 200.407 explains that approval may be sought to reduce later disputes about reasonableness or allocability, but absence of approval affects allowability by itself only where a cited rule requires it in the circumstances. Section 200.407 points to approvals involving:

• cost sharing (§ 200.306), program income (§ 200.307), budget/program revisions (§ 200.308), and fixed-amount subawards (§ 200.333);
• certain compensation for personal services (§ 200.430(h)) and fringe benefits (§ 200.431);
• equipment and other capital expenditures (§ 200.439) and exchange rates (§ 200.440);
• fines, penalties, damages, and settlements (§ 200.441); fundraising and investment management (§ 200.442); personal-use goods or services (§ 200.445); and insurance/indemnification (§ 200.447);
• organization costs (§ 200.455), pre-award costs (§ 200.458), rearrangement/reconversion (§ 200.462), and travel costs (§ 200.475).

Read the cited cost section and the award to determine the actual circumstances and approving authority. A category has not been “pre-approved” merely because it appeared in a broad budget. Conversely, § 200.407 does not make every instance of every listed cost unallowable without approval.

Recommended decision gate

Before committing, spending, rebudgeting, changing personnel, issuing a subaward, or extending work, document:

Question	Evidence	Stop condition
Does any § 200.308(f) trigger apply?	Current scope, budget, staffing, subaward and extension comparison	Yes: written approval first
Does a cost section require approval in these facts?	§ 200.407 cross-reference and specific cost rule	Yes: written approval first
Does the award add an applicable threshold or procedure?	Current award and agency terms	Follow it before action
Is the change within appropriation, scope, period, and available funding?	Program/legal/finance review	No: do not implement
Is this a qualifying self-initiated extension?	Express award authority and § 200.308(g)(2) evidence	Any exception: request approval
Is a pass-through entity the approving party?	Subaward terms and notices	Route to authorized party

This table is a recommended internal practice, not an agency approval form. Under § 200.308(c), submit budget revisions in the application budget format unless the agency approves another format, including an approved electronic system or email. The reviewer should receive the reason, before/after budget, cumulative transfer calculation, scope and milestone effect, cost-share effect, funding effect, effective date, and authorized-official certification. Under § 200.308(d), the reviewing party should respond within 30 days or state in writing when a decision is expected; silence is not approval.

Immutable version and control workflow

Use an append-only approval trail. The following is recommended, not a Uniform Guidance software mandate:

1. Freeze the baseline. Preserve the signed award, incorporated budget, scope, and every amendment as immutable versions.
2. Open a change record. Give the request an ID; record proposer, date, reason, affected categories, cumulative transfers, scope, personnel, period, cost share, subawards, and cost items.
3. Run all gates. Finance, program, and the authorized organizational representative review against § 200.308, § 200.407, and award terms.
4. Submit without implementing. Store the exact package and delivery receipt. Mark it “submitted,” never “approved.”
5. Capture the authoritative response. Preserve written approval, denial, questions, conditions, effective date, and any formal amendment. Verify the sender's authority.
6. Create—not overwrite—the next baseline. Link old and new versions and summarize every changed field.
7. Implement from the approved version. Update operational budgets, forecasts, purchasing gates, subawards, calendars, and reporting mappings. Notify affected staff.
8. Reconcile. Test the first post-change QBO and grant reports against both the effective date and approved categories.

For initial award controls, use the Federal award intake matrix. For category design, see grant budget versus actual in QBO.

Implementing with QBO and GrantLink

QBO is the accounting source of truth. Preserve posted source transactions and use controlled, dated corrections only when the accounting is wrong. A budget revision usually changes the approved comparison baseline and prospective spending authority; it does not itself justify rewriting historical accounting.

In GrantLink, retain the approved budget and amendment evidence, then update the grant's budget and operational controls from the authorized version. Ordinary QBO Expenses and Money received links are per grant. Shared Settings > QuickBooks Mapping is only for restriction-release accounts; it is not a funder-budget crosswalk. Reports start in Chats > New Chat. GrantLink does not automatically rewrite QBO, grant approval authority, or make a cost compliant.

Recommended implementation check: reconcile old and new category totals, effective date, cost share, funding, and QBO-linked population; then separately review each affected transaction for allowability, allocability, period, support, procurement, and approval.

Recovering from a premature change

Do not backdate a request, alter history, or describe pending approval as received. A recommended recovery protocol is:

1. stop further affected commitments, charges, draws, and reporting where practical;
2. preserve QBO entries, approvals, communications, submitted reports, and the chronology;
3. identify the complete affected population and whether scope, key personnel, participant support, subawards, cost share, funding, construction, extension, or a cost-item rule was involved;
4. escalate to the authorized official, finance and program leads, and legal/CPA advisers as appropriate;
5. disclose promptly to the agency or pass-through entity when required and request written direction or retroactive approval—without assuming it will be granted;
6. segregate questioned costs and avoid drawing or claiming them pending resolution;
7. if approval is denied, reverse or transfer costs only to a valid benefiting funding source under documented accounting and cost-allocation rules, repay funds or correct reports as directed, and address program consequences; and
8. preserve the final decision, adjustments, repayment, report resubmission, and control remediation.

Moving a cost to another Federal award merely to cure a deficiency is not acceptable. Any transfer must be independently allowable and allocable to the receiving award. Read how to allocate expenses across grants and audit-ready documentation.

Sources

• 2 CFR 200.308, Revision of budget and program plans
• 2 CFR 200.329, Monitoring and reporting program performance
• 2 CFR 200.403–200.407, Basic cost considerations and prior written approval
• 2 CFR 200.439, Equipment and other capital expenditures
• 2 CFR 200.458, Pre-award costs

Primary authorities checked against the eCFR available August 2, 2026. This practitioner guide is not legal or accounting advice.