Under limited circumstances, principal investigators (PIs) may request authorization to spend funds in support of their sponsored projects before they have notices of awards from sponsors. Authorization of pre-award spending is contingent upon the following:
- An essential need to advance or commit funds prior to the receipt of an award;
- Approval of human subjects, animal and/or biosafety protocols, as applicable;
- Approval of financial disclosures on the federal financial disclosure form and/or the state financial disclosure form 700-U, as applicable;
- Approval of exception to principal investigator eligibility, as applicable;
- Certification by the PI that the level of effort, scope and objectives of the project as proposed or negotiated will not change;
- Certification by the PI along with the approval from the appropriate dean and the vice chancellor for Research and Economic Development, that any monetary loss to the campus resulting from the sponsor's failure to make the award, or from costs incurred but disallowed by the sponsor, shall be the responsibility of the PI and backed up by the funding source provided on the pre-award spending form; and
- Receipt of a firm commitment by an authorized representative of the sponsor to the SPO that an award is forthcoming
Pre-Award Spending: Risks, Liabilities and Limitations
The risks, liabilities and limitations associated with pre-award spending must be carefully considered before requesting authorization to spend funds in advance of receiving the award.
Risks: Whenever the university authorizes pre-award spending, the university is risking monetary loss. The requesting PI must identify other funding that must be available to cover the risk of a delayed start date, costs disallowed by the sponsor or failure of the sponsor to make an award as anticipated.
Liabilities: Special care must be exercised in assessing the impact of pre-award spending on legal obligations of the university before requesting or approving pre-award spending. The university must consider the impact of not having a fully executed grant or contract agreement on its legal obligations regarding intellectual property rights, subject injury, indemnification, etc.
Limitations: A sponsor's policies, the terms and conditions of the anticipated award, campus policies and practices determine whether pre-award spending or pre-award activities are allowable. Restrictions differ depending on the funding agency and the type of award anticipated (i.e., grant, cooperative agreement or contract).
Requesting Pre-award Spending
When requesting pre-award spending please complete the Pre Award Spending Form.
Once the form is completed and signed, submit to the SPO to secure a firm commitment from the sponsor's authorized representative. The SPO will analyze the request to verify all administrative requirements have been met. If such requirements have been met, the SPO will secure a firm commitment from the sponsor's authorized representative.
If the sponsor provides a firm commitment, the SPO will then approve the pre-award spending and forward it to Contract and Grant Accounting for account/fund number assignment.
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