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Spending Before an Award Starts


Sample Request Letter

The purpose of pre-award spending is not simply to start a project early, but rather to make expenditures which would facilitate beginning the project on the specified start date.

For example:

  • Purchasing supplies and equipping a lab
  • Purchasing equipment when a sale price is only available before the start date
  • Making employment offers for project staff


    NOTE:
    All costs incurred must be allowable under the potential award. All pre-award costs are incurred at the recipient's risk. A sponsor is under no obligation to reimburse such costs if for any reason the recipient does not receive the award, or if the award is less than anticipated and inadequate to cover costs. The principal investigator's department will have to absorb any costs which are disallowed or not covered by an award.

Pre-award Spending with Federal Funds
Uniform, government-wide regulations govern pre-award spending on federal grants. If a project has been recommended for funding, federal agencies have several options. They may:

  • prohibit pre-award spending
  • require written agency approval
  • allow universities to incur pre-award costs 90 days prior to an award without prior written agency approval
  • exercise the default position provided in the regulations, as follows: If a federal agency does not explicitly address pre-award spending in its regulations or in the terms and conditions of an award, and if the award supports research, the requirement for prior written agency approval is automatically waived. The authority to approve requests for pre-award spending is transferred to the University.
  • Pre-award spending more than 90 days prior to the start date of an award must always be approved by the agency.

Pre-award Spending with Non-federal Sponsors
Research Support will contact non-federal sponsors on behalf of principal investigators who wish to initiate pre-award spending to determine if it is permissible, and if so, what procedures should be used.

Procedures
Steps if sponsor approval is required:

  1. A letter describing the need to incur expense before the proposed start date of the award should be addressed to the sponsor. The letter should be addressed to whomever told the principal investigator that the project was recommended for funding. This will usually be a program officer.
  2. The request must be countersigned by Research Support before submission.
  3. When approval is received, Research Support will authorize Sponsored Programs to establish an account for the project

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Steps if in-house approval is allowed:

Step1: The request should be addressed to the principal investigator's contact in Research Support. It must be signed by the department chair, or if the principal investigator is in a professional school, the dean. The letter should:

  • explain why pre-award spending is necessary
  • specify the requested start date
  • clearly state that the department, or school, will take responsibility for any expenses incurred if the funds are not received
  • include the name and phone number of the agency representative, usually a program officer, who told the principal investigator that the project had been recommended for funding


Step 2:  To minimize the financial risk for the department or school, Research Support will contact the agency. The level of risk is low if the program officer has sent the proposal to the agency's administrative office for processing and if the officer does not anticipate any delays.

Step 3:  If the level of risk is low, Research Support will authorize Sponsored Programs to establish an account for the project.