Policies, Procedures and Guidance

GIM 09 – Advance Spending on Sponsored Awards

Contents

Purpose

This policy sets out the parameters and requirements for expending funds in support of a sponsored award prior to award acceptance and during temporary extensions.

Background

Some awards may include pre-award spending authority. This can be either allowed for in the sponsor regulations or with written authorization from the sponsor’s authorized representative. When award issuance or negotiations are underway and a Principal Investigator (PI) may wish to incur costs, it is recommended that those costs are tracked on the award in the UW Financial system

The University provides a mechanism by which a Principal Investigator can request for advance spending to be set up in the UW Financial system or request a temporary extension on a currently funded award. This ensures that costs are allocated to the correct funding source at the time of expense. It also reduces risks associated with later transfer of expenditures.

University Policy

All costs in support of an award must be in compliance with GIM 23 including costs incurred prior to the acceptance of an award. Disallowed costs must be transferred to a non-award funding source.

By initiating an advance spending mechanism, the Advance Preparer is agreeing that:

• The Advance Preparer has authority to initiate the needed action, including providing a non-award funding source. Such authority should be documented within the department as required by GIM 2.
• The Advance Preparer is acting on behalf of the PI to make required assurances with respect to both fiscal and non-fiscal compliance
• An award is anticipated or currently being processed.
• The request is consistent with the sponsor’s policy and award terms and conditions
• The information provided in the request is complete, accurate, and related to the anticipated award

The PI will be responsible for any pre-award costs that are subsequently not allowed by the sponsor as well as any amounts incurred on the advance but not funded by the sponsor. The alternative department worktag provided at time of the advance spending request will be charged.

Non-Fiscal Compliance Requirements

All advance spending, including temporary extensions, must have required approvals including, but not limited to:

• Institutional Review Board (IRB ) approval or Exempt Status Determination if human subjects research costs to support the project will be incurred in advance
• Institutional Animal Care and Use Committee (IACUC) approval if animal use research costs to support the project will be incurred in advance
• Significant Financial Interest (SFI) disclosures must be made and reviewed for the subject eGC1

Monitoring

Costs incurred in advance of an award must be monitored by the PI, or their designee, to ensure compliance with GIM 23.

Timeframe

Advance spending beyond one year is subject to review by Grant and Contract Accounting (GCA) except in cases where the project is an industry sponsored clinical trial. For industry sponsored clinical trials, advance spending beyond 18 months is subject to review by GCA.

Procedures and Guidance

At any time after the proposal containing the anticipated costs is formally submitted to the sponsor and OSP has approved the eGC1, the PI or delegate may initiate the process to obtain:

• a new advance
• a renewal advance or
• to temporarily extend an existing award in anticipation of sponsor approval

Responsibilities

Principal Investigator/Delegate

• Completes a request for advance spending
• Provides assurances regarding fiscal and non-fiscal compliance
• Obtains concurrence/approval when required
• Responsible for monitoring all advance spending costs
• Responsible for all costs incurred prior to acceptance of the award that are subsequently not allowed by the sponsor as well as any amounts incurred not funded by the sponsor

Chair and/or Dean

• Concurs on advance spending if required
• Ensures that the department, school or college follows the University deficit resolution policy

Office of Sponsored Programs

• Maintains advance spending policy in coordination with Grant and Contract Accounting (GCA)
• Review temporary extension requests and submit to GCA

Grant and Contract Accounting

• Reviews and processes advance spending requests in the University’s systems
• Conducts additional reviews for requests that exceed the designated timeframe

Other Related Resources

• Sponsored Awards: Acceptance and Compliance: GIM 2
• Significant Financial Interest Disclosure Policy: GIM 10
• Accounting Adjustments on Sponsored Awards: GIM 15
• Activities Involving Human Subjects, Including Clinical Research: GIM 20
• Sponsored Program Costing Policy: GIM 23
• Use of Experimental Animals: Regulations – GIM 27
• Advance Spend
• Temporary Extensions
• SAGE Help Guidance

Content Creator

Responsible University Office
Grant and Contract Accounting / Office of Sponsored Programs

Change Notes

Details on changes to this GIM are available from the Office of Sponsored Programs, osp@uw.edu