PreAward Administration
Introduction
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.
PreAward Spending
Background and Contingencies
Under limited circumstances, 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). 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;
- 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 Exception to Principal Investigator 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 FAU 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 FAU ("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), authorize 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).
Requesting PreAwards
PreAwards are requested via the On-Line PreAward Request
System. For further details on utilizing that system or to
submit a PreAward request, please visit the On-Line
PreAward Request Application website.
Requesting Modifications to Previously Approved PreAwards
In exceptional circumstances, it may be necessary to increase
the expenditure level and/or PreAward performance period previously
authorized through the On-Line PreAward Request System. To
seek such a modification AND provided the fully executed award
associated with the initial PreAward request has not subsequently
been received and processed through PAMIS, please select the
"Modify PreAward Requests Previously Approved by the Office of
Research" function via on the On-Line PreAward Request System.
PreAward Policy
Please refer to
Campus Policy Number 550-80 for additional information
pertaining to PreAwards.
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