|Policy Approval Authority||President|
|Responsible Division||Division of Research and Innovation Partnerships|
|Responsible University Office||Sponsored Programs Administration|
|Responsible Officer(s)||Assistant Vice President|
|Contact Person||Dara Little, firstname.lastname@example.org|
|Effective Adoption Date||03-22-2010|
|Last Review Date||01-01-2017|
Sponsored Funding/Grants and Contracts
This policy outlines the requirements for obtaining a grant account number before the sponsored award process is complete and for incurring costs on a grant account outside of the official project start and end dates.
Reason for Policy
There are instances when a Principal Investigator (PI) may need a grant account (44 fund) to initiate charges on a sponsored project before the formal award process is complete. Rather than charge expenses to a non-sponsored “local” account and having to process cost transfers after the award is officially executed, the grant account can be set up to enable the PI to begin work related to the sponsored project. This process is often referred to as setting up a contingency account. A contingency account is not actually set up during this process. The contingency account is for back up purposes only and is only used to cover expenses deemed unallowable under the award or if the award is not received.
- Senior Administration – Vice Provosts, Associate Deans
- Directors, Department Chairs, Division Heads
- Faculty and Staff
- Departmental/Divisional Business Administrators
- Finance Personnel
- Sponsored Programs Administration Personnel
Principal Investigators who wish to obtain a grant account to incur charges on a sponsored project before the formal award process is complete must receive approval from their Department and Sponsored Programs Administration. This review and approval is necessary to mitigate the risks associated with incurring expenses before the award process is complete. It is ultimately the PI’s department that assumes the risk because any costs incurred on the grant account that are not covered by the award will be charged to the department pledged contingency account.
Some primary risk factors include:
The PI may assume that the project start date will be the same as the date listed in the proposal or be a date that is identified during informal discussions with the sponsor. However, the sponsor may not process the award in a timely fashion and the project start date may be later than the PI anticipated. If the sponsor is not willing to back date the project start date of the award to allow the costs incurred to be charged to the grant, the costs will be moved from the grant account and charged to the department pledged contingency account.
For contracts, many sponsors may consider the start date of the project to be the date of final signature; spending cannot begin until the contract is signed. Because contracts often require some level of negotiation, processing times can vary so it is difficult to know what the date of final signature will be.
Note: The start date of the project for many State of Illinois contracts is date of last signature.
- The sponsor may request that the PI reduce the proposal budget or remove certain categorical items during the award negotiation process. The PI should be certain of the final budget that will be approved by the sponsor before incurring costs on a grant account. Any costs that are greater than the award amount or deemed unallowable by the sponsor will be moved from the grant account and charged to the department pledged contingency account.
Advance AccountAn advance account allows the PI to obtain the grant account number before the formal award is fully executed. Usually, advance accounts are used to initiate HRS paperwork for grant related personnel and for procurement purposes. An advance account may only cover costs incurred within the project period identified in the sponsor’s award.
Pre-Award SpendingPre-Award spending is similar to setting up an advance account with one distinct difference. With pre-award spending, work may begin and project related expenses can be charged to the grant account prior to the project start date indicated on the sponsor’s notice of award. Federal regulations provide for pre-award costs on grants up to 90 calendar days before the award. Some agencies require prior approval to incur pre-award costs while others waive this requirement and transfer approval authority to the grantee (i.e. NIU). Both the National Science Foundation (NSF) and National Institutes of Health (NIH) allow the grantee to approve pre-award spending. Always check with SPA to determine sponsor approval requirements. Break between Budget Periods (i.e. bridge spending)
Some PIs may have an incremental award; where in the sponsor agrees to fund a specific number of years at a pre-determined amount per year as long as the project is progressing and the sponsor has funding available. A request can be made to keep the grant account active to continue paying personnel to ensure continuity of the project while waiting for the sponsor’s next funding increment to be received. PIs may also seek bridge spending when a no cost extension request is in process with the sponsor.
Reminder: The decision to incur project expenses before receiving a fully executed award or approval for a no cost extension must be made prudently and should be considered only when there is sufficient documentation that an award is imminent and the terms and conditions of the award are known.
All costs incurred must be:
- Allowable and in accordance with applicable regulations
- Included in the proposal budget; and
- Necessary to conduct the project.
The PI must complete a Electronic Institutional Prior Approval Request (IPAS) and submit it to SPA to establish a grant account. The IPAS requires the PI to identify a contingency account. The department or college generally provides the account. The account can be a 02 or 41 account, but cannot be another grant (44 fund) account.
Reminder: The contingency account will only be used to cover any expenses that are deemed to be unallowable under the award or if the sponsor fails to issue an award.
SPA will make every effort to review the request within 48 hours or two business days. However, review of the request in no way guarantees that it will be approved within this 48-hour time frame.
Upon SPA approval, the Grants and Contracts Associate (GCA) will set up an account in PeopleSoft, or for bridge spending, allow the PI to continue spending on the existing grant account. The PI, Department Chair/Unit Head, and individual signing for the contingency will receive electronic notice when the request has been approved. If SPA must set up a new account, the notice will include the grant account number.
Note: Changes to advance account, pre-award, or break in budget period spending requests must be submitted through SPA and may require a new Contingency Fund Availability Form. Such changes include (but are not limited to) extending the fund availability dates and increasing the amount.
Policy Questions and Waiver Approvals
Kellie Dyslin, Associate Director, Pre-Award Support
For advance accounts and pre-award spending:/h4>
Rachael Andel, Award Coordinator
For spending between budget periods:
Contact your Grants and Contracts Associate
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