Under limited circumstances, Principal Investigators (PIs) may request authorization to spend funds in support of a sponsored project in advance of receiving a notice of an award from a sponsor if such costs:
- are necessary to conduct the project, and
- would be allowable under the grant, if awarded, without prior approval
The risks, liabilities and limitations associated with pre-award spending must be carefully considered prior to requesting authorization to spend funds in advance of receiving the award.
The PI must identify another funding source (typically an ICC or Departmental account) 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. Pre-award costs will not be approved unless the Department Head/Chair or the Dean/Director guarantees to reimburse the University in the event the award is not received.
The direct costs on the requested pre-award index will be covered by the non-grant fund authorized by the Department Head/Chair or a Dean/Director if the award is not made to the University, or if the costs incurred are unallowable under the terms of the actual award.
On the Pre-award Spending Request Form requesting a Pre-award Index which is submitted to SPS, there is a place to enter a dollar amount which reads, "the total direct costs for this request are not anticipated to exceed the following amount."
The Department Head, by signing the Pre-award Spending Request Form, certifies that in the event the award for the project is not actually made to the University, or costs incurred are unallowable under the terms of the actual agreement, the direct costs on the Pre-award index, even if in excess of the anticipated amount of direct costs noted on the Pre-award Spending Request Form by the PI, will be covered by the non-grant fund authorized by the Department Head as the Guarantee Fund/Index."
- Pre-award spending requests should be no more than the Total Direct Costs of Year 1.
- On a case-by-case basis, dependent on the status of the Contract or Award, SPS may request the department to increase or decrease the guaranteed amount (guaranteed by the UO department) on the Request for Advance Account # (Pre-award).
Regulatory Compliance
The University does not permit the creation of a pre-award index until all compliance protocols have been submitted, reviewed and approved by the appropriate regulatory offices. An advance spending account cannot be established prior to meeting the following regulatory compliance criteria:
- All individuals responsible for the design, conduct, or reporting of the sponsored program have completed FCOI Training and submitted the Declaration e-form. If this request is to incur allowable pre-award expenses, all related FCOI disclosures must be submitted and current through the anticipated award start date.
- All animal protocols are approved and determined to be congruent to the proposal by the Institutional Animal Care and Use Committee (IACUC).
- All human subject protocols are approved and determined to be congruent to the proposal by the Institutional Review Board (IRB).
- All other regulatory compliance requests (biohazards, radiation safety, hazardous material, etc.) are on file and approved.
Pre-award Requests Involving Contracts
Under limited circumstances, Principal Investigators (PIs) may request authorization to spend funds in support of a sponsored project that will be funded via a contract in advance of a fully-executed contract signed by both the UO and the Sponsor. Please note:
- The start date (or effective date) of the contract as it is described in the terms and conditions of the contract must be confirmed and stated on the Pre-award Spending Request Form.
- Depending on the complexity of terms and conditions associated with a contract, pre-award spending requests associated with contracts may require approval by the Contracts Officer at Sponsored Projects Services (SPS).
Reasons for Requesting a Pre-Award Account
Normally, expenditures may not be charged against sponsored programs before the effective date of a sponsored program award. However, late award receipt may be one reason, for example, for requesting a pre-award account due to delayed receipt of the award by the University.
Several Federal agencies have adopted expanded authority policies that are intended to reduce overhead costs, increase research productivity, and reduce paperwork.
Expanded authority includes the authority granted to the University which waives prior approval by certain Federal Sponsors allowing up to 90 days pre-award costs. Requests for more than 90 days require prior approval. Other Federal and/or non-Federal sponsors may require prior approval for pre-award spending, while other Federal and/or non-Federal sponsors specifically don't allow pre-award spending in advance of the start (or effective) date of the sponsored award.
Contact your Pre-Award Sponsored Projects Administrator for questions concerning pre-award spending.
To request a pre-award index, complete the Index Request Form (Smartsheet) and submit it to SPS for review and approval.