There may be an occasional need to begin work on a project prior to receipt of the fully executed award documents but within the start and end dates of the award (Advance Spending) or in advance of the start date of the project (Preaward Spending)
Pre Award Spending
Pre Award spending should only be incurred when required for the effective and economical performance of the project such as the ordering of equipment needed to begin the work.
Many federal agencies have given the University prior approval to begin spending up to 90 days before the start date of the award if certain requirements are met. If the sponsor has not given the university prior approval, approval must be requested from the sponsor. No pre award expenditures should be incurred without written approval from the ORA and the sponsor if required. Once a need for pre award spending is noted by the PI, a request should be submitted to the ORA. The ORA will determine if sponsor approval is required. If sponsor approval is required, ORA will request the pre award spending approval from the sponsor.
If the university has been granted prior approval, the Manager of Pre and Post Award Services or the Director of ORA will review the request and make the determination.
Incurring such expenditures is at the PI’s own risk, the sponsor is not obligated to reimburse the University if the award is not issued or is issued at a lesser amount than requested. Therefore, any pre award spending request must include an unrestricted account to which the expenditures will be transferred if the sponsored funding does not occur as planned. Also, if the agency delays the start date, any pre award expenditure incurred more than 90 days prior to the actual start date would need specific approval from the agency.
Spending within the award period but before a fully executed award document is received by the University is also undertaken at the risk of the PI in the event that the award start date is changed, funding is not received or the funding level is decreased. Some state agencies refer to the date the agreement is signed as the start date of the project, this date can be different than the originally anticipated start date.
Once a need for advance spending is noted by the PI, a request should be submitted to the ORA.
All advance spending requests must include an unrestricted account to which the expenditures will be transferred if the sponsored funding does not occur as planned. Also, if the agency delays the start date, any advance expenditure incurred prior to the actual start date would need specific approval from the agency. Advance spending should only be incurred when required for the effective and economical performance of the project such as the ordering of equipment needed to begin the work
Requesting a Pre Award or Advance Account
All requests are to be submitted to ORA, Manager of Pre and Post Award Services using the Advance/PreAward Cost Account Request Form. The form is to be signed by the PI and Department chair.
The forms are sent to ORA and reviewed; if sponsor approval is required ORA will submit a request to the sponsor. Where sponsor approval is not required ORA will determine if there is significant likelihood that an award will be received and determine if an account should be established.
No spending should be incurred until written authorization is received from ORA and the sponsor as required.
Prior to establishing Advance or Pre Award Accounts the following conditions must be met:
- ORA must have received and approved a complete proposal package – Routing Form, Conflict of Interest Summary Form, Budget and Application
- All regulatory compliance approvals (IRB, IACUC, etc.) must be in place
- Dates for an advance account must be within the anticipated award period and for a preaward account the start date must be within the sponsor allowed preaward period.
- A budget for the amount of the advance or preaward request must be provided; the budget will normally be limited to the amount needed within 90 days.
- An unrestricted account number/fund must be provided in the event the award is not made as anticipated or any other problems occur.
- The PI and Department Chair must approve all requests and agree to accept financial responsibility of any disallowed expenditures.
- In order for expenditures to be allowed as advance or pre award spending, they must meet all of the allowability requirements of federal, state and sponsor policies and guidelines.
Establishing the Advance or Pre award Account
- Once the advance or pre award account has been approved, ORA will establish the account and send an account memo.
- ORA will review all Advance/PreAward accounts in 90 days and determine status of awards.
- Once an award document is received, the account will be converted to awarded status.
- If the account is not awarded the expenditures will be transferred to the unrestricted fund provided on the form.
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