Costs incurred within 90 days of the effective date of an award may be charged to an award provided the award falls under the “Expanded Authorities.” Principal Investigators, who have been given an indication that their proposals will be funded, may request authorization to spend funds for a sponsored project prior to final funding approval. Whenever pre-award spending is authorized, the university is risking monetary loss. Other department or college 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 an award as anticipated. A sponsor’s policies, the terms and conditions of the anticipated award, and campus policies and procedures determine whether or not pre-award spending or pre-award activities are allowable. Because of the manual interventions required for sponsors associated with the state’s Single Letter of Credit (WBS numbers beginning with ‘24’), pre-award spending is not recommended for these awards. Other restrictions differ depending on the funding agency and the type of award anticipated (i.e., grant, cooperative agreement, or contract).
Authorization of pre-award spending is contingent upon:
- the need to commit funds prior to funding approval in order to successfully complete the project
- provision for a university cost object to be charged if the award is not funded
- approval of human subjects, animal and/or bio-safety protocols as applicable
- PI certification that the request does not involve changes in the scope or objective of the award
- certification by the head of the unit responsible for administering the anticipated award, along with the appropriate college dean/departmental chair, that any monetary loss to the campus resulting from the sponsor’s failure to approve the award (or from costs incurred, but disallowed, by the sponsor) will be the responsibility of that department or college
- Office of Sponsored Program’s receipt of a written commitment that an award will be approved from an authorized representative of the sponsor
- Submission and Routing of the Institutional Prior Approval to Spend (IPAS) form (.pdf)
Requests for pre-award spending are routed on the Institutional Prior Approval to Spend (IPAS) form. The PI should complete the IPAS, explaining the need, providing a university cost object to be charged if the award is not funded, and providing copies of any correspondence from the sponsor documenting that an award will be made. The PI must sign and date the IPAS. This signature certifies that the scope and objectives of the project as proposed or negotiated will not change and that approval of the request is needed to successfully complete the project.
The department chair or the college dean must also sign the IPAS and check the appropriate boxes to indicate which unit will provide funding for any losses incurred as a result of approval of this request.
A completed and signed IPAS should be submitted to the Office of Sponsored Programs Post-Award staff to verify that all administrative requirements have been met. If so, Post-Award will establish a WBS number, complete the information on the IPAS, and provide confirmation of approval for pre-award spending to the requesting PI or unit.