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University of Louisville
 OFFICIAL
UNIVERSITY
ADMINISTRATIVE
 POLICY
 
 
University Community (administrators, faculty and staff)
 
POLICY NAME
PRE-AWARD SPENDING
EFFECTIVE DATE
July 1, 2004
POLICY NUMBER
RES-2.05
 
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.

 
HISTORY
 
Revision Date(s):  08/15/2012 | 12/03/2013 | 08/12/2015  
Reviewed Date(s):
 

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:  1-502-852-3788
Email:  grntmgmt@exchange.louisville.edu

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.

 
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