Research and Sponsored Projects Manual (RSP)

Effective: 2/17/1987

Revised: 10/14/2004

RSP 409: Spending on a Pending Federal Award Project Prior to its Designated Start Date

Purpose

To define the circumstances under which prestart date spending may be allowed on some federally funded projects

Sources

United States. Office of Management and Budget. OMB Circular A-21 (revised), Cost Principles for Educational Institutions

Office for Research and Sponsored Projects Administration

Specific applicable agency provisions or regulations

Policy

Normally, expenditures may not be charged to a sponsored project account prior to the start date specified on the award notice. However, some federal agencies allow requests for prestart date expenditures to be reviewed and approved within Arizona State University (ASU) through the use of the University Prior Approval System (UPAS).

Accounts may be established for prestart date spending if the following conditions exist:

1. the federal sponsor has granted expanded authorities to ASU
2. the project has been approved or recommended for funding by the sponsor, and the sponsor is processing an award notice
3. the principal investigator (PI) satisfactorily addresses the following factors in the request to establish a pre-award account:
   
   1. demonstrated low risk (i.e., the sponsor’s assurance that the award is being processed)
   2. justification to begin the project prior to the actual project start date
   3. specified start date for the pre-award account

      Note:

      Under expanded authority, the sponsors will only reimburse expenses made 90 days prior to the actual award date. If the actual project award date is later than the start date requested for the pre-award account, the PI, the department, and/or the college are liable for costs incurred prior to the 90 days before the actual award date.

      and

   4. projected budget for the pre-award account that is not more than 25 percent of the proposed annual budget or revised budget.

4. ORSPA concurs that all above criteria have been satisfactorily addressed.

Any expenditure on a pre-award account that is not allowable under federal, university, or sponsor regulations will be transferred to a nonsponsored account.

Note:

Some subfederal projects may allow (flowdown) expanded authorities.

Cross-Reference

For information on how to establish an account, see RSP 501, “Establishment of a Sponsored Project Account.”

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