The Office of Research and Economic Development (RED), through its Sponsored Programs Administration (SPA) unit, provides pre-award administration services to faculty, unit staff, and other central administrative offices. These services include, but are not limited to, the following:
- Reviewing and approving/endorsing requests to spend funds in advance of receiving a sponsored award;
- Reviewing and signing institutional certifications, representations and assurances;
- Facilitating sponsor requests for additional information about proposed programs, including requests for "just-in-time" information;
- Interpreting sponsor and university policies, and government regulations;
- Liaising with sponsors;
- Providing research administration training courses and consulting services; and
- Promoting and facilitating institutional compliance with government regulations.
Background and Contingencies
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 (PreAward).
PreAwards may be authorized for an expenditure of funds (i) in an amount up to a certain percentage of the anticipated award amount and (ii) incurred during a certain time period prior to the official start date of the award, contingent upon the sponsoring agency’s PreAward spending guidelines. A PreAward should be considered when, for instance, an official award has not been executed due to external delays or due to delays in contract negotiation, yet there is a firm project start date and award amount, and the project would be adversely affected by the delay.
Authorization for a PreAward is contingent upon the following:
- A critical need to meet project objectives must exist to expend funds in advance of a new, renewal or continuation award (e.g., the need to order/purchase equipment or the need to continue paying salaries & benefits when the next increment of funding has been delayed beyond the next budget period start date of a continuation award);
- Approval of human subjects, animal, biosafety or other research protocols by the appropriate regulatory committee, as applicable;
- Successful completion of the human subject tutorial by the PI and all key personnel participating on the project, if human subjects are involved;
- Approval of required financial disclosures, as applicable;
- Approval of Request for Exception to Policy Regarding PI 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 chair/director of the unit responsible for administering the anticipated award ("Departmental Approver"), 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 that unit or school. If, however, the Department Approver is unable to authorize the use of an alternate Chart of Account in the event losses are incurred as a consequence of the PreAward, then certification must be obtained by the appropriate dean or vice chancellor who's office will provide the use of an alternate COA ("Organizational Approver"); and
- Confirmation of the sponsor's firm commitment from an authorized representative of the sponsor by SPA; however, PreAward may proceed without the sponsor's firm commitment in the event that the Department Approver, or the Organizational Approver (as appropriate), has authorized the PreAward request despite the increased financial risk in doing so in the absence of the sponsor's firm commitment.
PreAward Spending - Risks, Liabilities and Limitations
The risks, liabilities and limitations associated with PreAwards must be carefully considered prior to requesting authorization.
Risks: Whenever the University approves a PreAward, it is risking monetary loss. Other funding must be available to cover the risk of a delayed start date, costs disallowed by the sponsor, or failure of the sponsor to make the anticipated award.
Liabilities: Special care must be exercised in assessing the impact of PreAwards on the legal obligations of the University, especially in the areas of intellectual property rights and indemnification, as well as other special award terms.
Limitations: A sponsor's policies, the terms and conditions of the anticipated award, and campus policies and practices determine whether or not a PreAward will be authorized. Restrictions differ depending on the type of sponsor and the type of award anticipated (i.e., grant, cooperative agreement, or contract).
To get started, a PreAward Spending Request must be submitted.
Requesting Modifications to Previously Approved PreAwards
It may be necessary to increase the expenditure level and/or PreAward performance period previously authorized via a PreAward Spending Request form. To seek such a modification (provided the fully executed Award associated with the initial PreAward request has not subsequently been received and processed through Kuali), please submit a "Modified PreAward Spending Request" form.
Please refer to Campus Policy #550-80 (PRE-AWARD POLICY) for additional PreAward policy and procedural information.