Pre-Award spending allows the Principal Investigator (PI) to charge cost incurred prior to the official start date of the award. When allowed by the sponsor, Pre-Award costs can be posted for expenditures up to 90 days prior to the award start date. The expenses must be necessary and allowable under the potential award. Pre-Award spending that is not approved by the sponsor, will be moved to a department’s cost center allocated by the academic unit. If the academic unit cannot provide a non-grant cost center within the time required, the expenses will be moved to the department IDC cost center.
The chart below outlines the steps, the responsible office or person, and the time it takes to complete the request for Pre-Award Spending.
|Steps||Responsible Office or Person||Timing|
Complete the Prior-Approval form and submit to OCG. Include the following:
|PI or Dept. Business Administrator (DBA)|
|Obtain acknowledgement or evidence that the award was issued or is forthcoming.
Also confirm that pre-award spending is allowed according to the award’s terms & conditions.
|OCG||5 business days|
|Setup the Award Profile and an associated Project Cost Center with the normal award start date. The project effective date would be set 90 days prior to allow expenses to post before the award start date.
Notify PI and DBA
|OCG||5 business days|
|Complete the award setup||OCG||Within 14 days of receipt of official NOA|
|Review the Project Cost Center and make corrections if expenses against the award are prior to the 90 days allowed||OCG||30 days after the award official end date|
Pre-Award spending is not the same as interim funding. Pre-Award spending allow expenses to be incurred before the award’s start date, while interim funding, allows spending during the period of performance only (begin and end date of award).
Post Award spending is never allowed except in very rear cases. During close out (90 days after the award end date) federal agencies may allow for the costs of publication or sharing of research results if the costs are not incurred during the period of performance (UG §200.461)
Spending for supplies and equipment in the last six (6) months of the grant could be disallowed if the justification provided does not clearly explain why the item is needed that late in the award stage.
In cases where a sub-recipient is associated with the award, the university will issue the subaward agreement once the official Notice of Award (NOA) is received. The agreement’s start date must be the same as the official NOA’s or later. However, if the sponsor’s terms and conditions allows pre-award spending and it is flown down to the sub-recipient, the sub-recipient can incur pre-award spending at its own risk.
The pre-award spending guidelines for transfer awards are similar to those of the regular awards. That is, the university must have written authorization from the prime grantor in order to incur pre-ward spending.