Pol-Pre-Award Spending

policy pre-award spending modified Thu Jan 30 2020 15:27:06 GMT-0500 (Eastern Standard Time)

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University of Louisville

OFFICIAL
UNIVERSITY
ADMINISTRATIVE
POLICY

POLICY NAME

Pre-Award Spending

EFFECTIVE DATE

July 1, 2004

POLICY NUMBER

RES-2.05

POLICY APPLICABILITY

This policy applies to the University Community (administrators, faculty, and staff).

POLICY STATEMENT

Prior to authorizing work and associated expenditures on an anticipated sponsored program the Principal Investigator or Project Director’s supervisor must request that the Office of the Executive Vice President for Research and Innovation (EVPRI) establish a chartfield with associated speedtype.

REASON FOR POLICY

Often a Project Director (PD) or Principal Investigator (PI) wishes to begin a project prior to the award date but rather than requesting a speedtype in advance of the award, expenses are placed on an existing speedtype. This practice significantly increases the number of salary and expense transfers if work begins prior to the formal award notice and/or contract execution.  This policy is to assure that costs incurred between beginning the work and formal notification of award or in advance of the award date do not require transfers but are posted originally to the correct speedtype.

RELATED INFORMATION

This policy does not apply to agencies that prohibit pre-award spending.  Pre-award spending on federal grants that allow pre-award spending will be limited to 90 days prior to the actual start date of the award.  Neither does this policy change the requirement that no subjects can be enrolled in clinical trials prior to Institutional Review Board (IRB) approval or, if a sponsored clinical trial, a signed agreement.  Pre-award expenditures must meet the same guidelines of allowability, allocability and reasonableness as described in 2 CFR 200.

DEFINITIONS

Office of the EVPRI – Office of Sponsored Programs Administration – Grants Division (SPA), Clinical Contracts Division (CCD), Office of Industry Engagement (OIE), as applicable. 

PROCEDURES

The request can guarantee funding in three ways: 

  • A guarantee for a certain type of expenditure(s), for instance salary and fringe benefits only.
  • A guarantee for a specified dollar amount in any category of the proposed expenditures.
  • A guarantee for the entire proposed project.

The request for a pre-award speedtype must be sent from the PI/PD through their business manager and their chair/unit head to the Director of OSPA, CCD, or OIE, as applicable.  The request must identify an unrestricted funding source to cover any expenses to be placed on the pre-award Chartfield/speedtype.  The request must be consistent with the Proposal Clearance Form (PCF) or Multi Institutional Research Application (MIRA) and provide a budget for expenses to be charged during the pre-award period.
 
When the actual award is made, funds from the award will be used to cover these authorized expenses.
 
If the University does not receive the award, the responsible department must move all charges to other, non-sponsored funding sources. If not removed by the department in a timely manner all charges will be moved by OSPA – finance division.


RESPONSIBILITIES

Deans, Directors, and Department Heads
 
Approval of establishing the pre-award Chartfield/speedtype and provision of an unrestricted funding source to guarantee pre-award spending.
 
Institutional Officials
 
OSPA/CCD/OIE representative is responsible for the establishment of new Chartfield/speedtypes.
 
VIOLATIONS OF THIS POLICY
 
Transfers of expenditure may not be authorized by the OSPA, CCD, or OIE for pre-award spending if no request for expenses is in the respective institutional office prior to the date of expenditure.

ADMINISTRATIVE AUTHORITY

Executive Vice President for Research and Innovation

RESPONSIBLE UNIVERSITY DEPARTMENT/DIVISION

Sponsored Programs Administration

Clinical Contracts Division
Industry Engagement
 

Sponsored Programs Administration

J.D. Nichols Campus for Innovation and Entrepreneurship
Louisville, KY 40292

Phone: 502-852-3788
Email: grntmgmt@exchange.louisville.edu 


HISTORY

Revision Date(s):  08/15/2012; 12/03/2013; 08/12/2015  

Reviewed Date(s): 


The University Policy and Procedure Library is updated regularly. In order to ensure a printed copy of this document is current, please access it online at http://louisville.edu/policies.