Policy / Procedure

Pre-Award Spending

I. PURPOSE / BACKGROUND

Often a Project Director (PD) or Principal Investigator (PI) wishes to begin a project prior to the award date but rather than requesting a speedtype in advance of the award, expenses are placed on an existing speedtype. This practice significantly increases the number of salary and expense transfers if work begins prior to the formal award notice and/or contract execution. This policy is to assure that costs incurred between beginning the work and formal notification of award or in advance of the award date do not require transfers but are posted originally to the correct speedtype.

POLICY

Prior to authorizing work and associated expenditures on an anticipated sponsored project the project director’s supervisor must request that the Office of Grants Management (OGM) or the Office of Industry Contracts (OIC) – dependent upon the type of sponsor – establish a chartfield with associated speedtype.

ORGANIZATIONAL RESPONSIBILITIES

Deans, Directors and Department Heads

Approval of establishing the pre-award Chartfield/speedtype and provision of an unrestricted funding source to guarantee pre-award spending.

Institutional Officials

OGM/OIC representative is responsible for the establishment of new Chartfield/speedtype.

VIOLATIONS OF THIS POLICY

Transfers of expenditure will not be authorized by the OGM or the OIC for pre-award spending if no request for expenses is in the respective institutional office prior to the date of expenditure.

PROCEDURE FOR POLICY

The request can guarantee funding in three ways:

· A guarantee for a certain type of expenditure(s), for instance salary and fringe benefits only.

· A guarantee for a specified dollar amount in any category of the proposed expenditures.

· A guarantee for the entire proposed project.

The request for a pre-award speedtype must be sent from the PI/PD through their business manager and their chair/unit head to the Director of OGM or OIC.  The request must commit a non-sponsored funding source to cover any expenses that are not covered by the award. The request must be consitent with the Proposal Clearance Form (PCF)/Multi Institutional Research Application (MIRA) and provide a budget that must include salaries if they are to be charged

Subject: Pre-award spending for Sponsored Agreements	Policy and Procedure	Page 1 of 2
Author: Office of the Senior Vice President for Research	Effective Date: 07/01/04	Revised Date:

Policy / Procedure

during the pre-award period and indicates by account other authorized expenditures.

When the actual award is made, funds from the award will be used to cover these authorized expenses.

This policy does not apply to agencies that prohibit pre-award spending. Pre-award spending on federal grants that allow pre-award spending will be limited to 90 days prior to the actual start date of the award.  Neither does this policy change the policy that no subjects can be enrolled in clinical trials prior to Human Studies Committee/IRB approval or, if a sponsored clinical trial, a signed agreement. Pre-award expenditures must meet the same guidelines of allowability, allocability and reasonableness as described by OMB Circular A-21.

If the University does not receive the award, the responsible department must move all charges to other, non-sponsored funding sources.

This policy replaces the process described in section 5.4 of the Grants Management Handbook.

Subject: Pre-award Spending for Sponsored Agreements	Policy and Procedure	Page 2 of 2
Author: Office of the Senior Vice President for Research	Effective Date: 07/01/2004	Revised Date: