Research OSPA:Pre Award Funding Process

From Office of Research Wiki
Jump to navigation Jump to search

Effective Date

September 1, 2013

Statement of theIssue

Procedures to follow when initial funding by sponsor of an awarded project is delayed.

Applicable Policy/Regulation

If there is a delay in the receipt of an award, the Principal Investigator (PI) may request a pre-award in order to begin work on the project while the award is being processed or negotiated. (See Uniform Guidance 2 CFR 200.209 and 200.458.) Pre-award can only be requested if there is written confirmation from the sponsor that an award is forthcoming, and such confirmation includes the start date for the new award and the anticipated funding level.Some federal sponsors have granted institutions expanded authority under the Federal Demonstration Partnership (FDP) to approve 90 days of pre-award costs, as long as costs are both necessary to conduct the project and allowable under the terms of the anticipated award. (See, e.g., NIH Grants Policy Statement – Part II: Terms and Conditions of NIH Grant Awards, Administrative Requirements, Section 8.1.2.13).

Process

  1. If there is a delay in the receipt of an award, the Office of Sponsored Projects (OSP) can request pre-award funding – funds covered by the Dean for a predetermined amount of time - until the actual funding is received.
  2. In order to process a pre-award funding request, the Grants Specialist must have written confirmation from the sponsor that an award is forthcoming, and such written confirmation includes the start date of the project and anticipated funding level.
  3. The PI will need to determine the amount of time needed – not to exceed 90 days - and provide a budget for this time period. The budget must align with the original submitted and approved sponsor budget, and should be pro-rated based on the length of the pre-award. (For example, 90 days of pre-award should roughly equal 25% of the funds awarded over a 12 month project period.) If applicable, the following documents will also need to be provided by the PI to the Grants Specialist: verification of Institutional Animal Care & Use Committee (IACUC) approval of the project’s proposed use of live vertebrate animals; certification of Institutional Review Board (IRB) approval of the project’s proposed use of human subjects.
  4. Once the Grants Specialist receives the budget, time frame and all applicable certifications, a pre-award request letter will be prepared and sent to the respective Dean of the PI’s school for approval. Included with the letter is written confirmation from the sponsor that an award is forthcoming. The template of the letter can be found at the end of this process and at

G:\Sponsored Projects\TEMPLATES\Forms\Pre-award Letter .

  1. Once signed, the Grants Specialist will use the pre-award letter in place of an award letter and follow the procedures in the Award process located at G:\Sponsored Projects\Processes\Grant Processes\Award.
  2. For additional information, refer to the <a class="wiki external" target="_blank" data-cke-saved-href="https://research.utdallas.edu/wiki/guidelines/opm/setting_up_cost_center" href="https://research.utdallas.edu/wiki/guidelines/opm/setting_up_cost_center" rel="external">Office of Post Award Management (OPM) process</a>.

Restrictions

A pre-award request cannot be approved in the following circumstances:

  1. Pre-award spending is not allowed unless specifically approved by your award agreement.
  2. Pre-award spending is not allowed on contracts.
  3. The effective start date of the project is tied to the date of final signature on the award agreement. In such cases, spending cannot begin until the award or contract is fully signed.
  4. The University informed the sponsor at the time of proposal submission that the University reserved the right to negotiate the terms and conditions of any award that might result.
  5. There is indication (based on prior experience with the funding agency or information contained in the proposal guidelines) that award terms and conditions will conflict with University policy and a protracted negotiation period is likely.

Definitions

  1. Pre-award - If an award for a new project is delayed by a sponsor, the Dean can approve funding for a predetermined amount of time until the actual funding is received from sponsor.
  2. Institutional Animal Care & Use Committee (IACUC) - The PHS Policy on Humane Care and Use of Laboratory Animals incorporates the U.S. Government Principles for the Utilization and Care of Vertebrate Animals used in Testing, Research, and Training, and requires the grantee to maintain an animal care and use program based on the Guide for the Care and Use of Laboratory Animals. An Institutional Animal Care and Use Committee (IACUC) appointed by the Chief Executive Officer or designee, is federally mandated to oversee the institution's animal program, facilities, and procedures (Public Law 99-158, Sec. 495). IACUC review and approval is required for all PHS supported activities involving live vertebrate animals prior to funding.
  3. Institutional Review Board (IRB) - An administrative body established to protect the rights and welfare of human research subjects recruited to participate in research activities conducted under the auspices of the organization with which it is affiliated. The Institutional Review Board has the authority to approve, require modifications in, or disapprove all research activities that fall within its jurisdiction.
  4. Federal Demonstration Partnership (FDP) – A cooperative effort among federal research agencies and recipients of federal funds aimed at reducing the administrative burden associated with research grants and contracts. FDP implemented streamlined terms and conditions for research grants.

Uniform Guidance - In effect December 26, 2014 and published by the federal <a class="wiki external" target="_blank" href="http://www.whitehouse.gov/omb/grants_docs

" rel="external">Office of Management and Budget (OMB)</a>, this guidance supersedes and streamlines requirements from OMB Circulars A-21, A-87, A-110, and A-122; Circulars A-89, A-102, and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up. This guidance provides a governmentwide framework for grants management which will be complemented by additional efforts to strengthen program outcomes through innovative and effective use of grant-making models, performance metrics, and evaluation.

Example

March 22, 2016
MEMORANDUM
TO: Name of PI’s Dean +Dean, PI’s School +FROM: OSP Specialist +SUBJECT: Pre-award for Dr. PI name Project: title of project
Authorization to establish pre-award spending is respectfully requested for a type of project, with Name of Sponsor under the direction of PI name. [[Reason the pre-award is being requested. Example: “As indicated in the attached correspondence, DOE is currently processing the award documentation and anticipates releasing the award shortly. Due to the administrative delays, and in order to support personnel working on the project, Dr. Smith respectfully requests a pre-award cost center be established.”]]Pre-award Period Requested: Enter dates the pre-award will be active – typically a 90 day periodPre-award Funding Requested: $ +Total Amount of Anticipated Award: $
By signing this request, PI’s School will cover all expenditures incurred from Pre-award period, in the event the Sponsor fails to provide funding.
If the above meets with your approval, please sign below and return original via email.
Approval___Name of PI’s Dean