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Advance Spending Requests FAQ

Find answers to common questions about advance spending requests.

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What is an Advance Spending Request?

At the request of the Principal Investigator (and with approval/support of the Department Chair/ORU Director and MSO/DBO) an Advance Spending Request allows the University the ability to establish a fund/index prior to receipt of an award.  The fund/index number set up via this process is applicable to the award when it arrives, thus eliminating the need for any cost transfers.

An Advance Spending Request applies primarily to federal grants and cooperative agreements.

At the request of the Principal Investigator (and with the approval of the Department Chair/ORU Director and MSO/DBO) an Advance Spending Request allows the University the ability to establish a fund prior to receipt of an award and to incur costs up to 90 days in advance of the anticipated start date for an award (if allowed by sponsor policy).

Advance Spending Requests help to alleviate cost transfers on to federal funds and potential misallocation of costs.

Authorization of pre-award spending is contingent upon the following:

  • An essential need to advance or commit funds prior to the receipt of an award;
  • Approval of a PI Exception, as applicable;
  • Approval of human subjects and/or animal subjects protocols, as applicable;
  • Approval of financial Conflict of Interest disclosures, as applicable;
  • Understanding by the Principal Investigator that the level of effort, scope, and objectives of the project as proposed or negotiated will not change;
  • Certification by the PI (along with the approval from the Department Chair/ORU Director and MSO/DBO) that any monetary loss to the campus resulting from the sponsor's failure to make an award, or from costs incurred but disallowed by the sponsor, shall be the responsibility of the PI and absorbed by the alternate non-federal, unrestricted funding source provided on the Advance Spending Request;
  • Receipt of sufficient assurance from the sponsor of a high likelihood of funding; documentation may include emails, NSF FastLane status, NIH eRA Commons status, and any other similar materials from the sponsor that demonstrate that funding is expected and in-process.
  • Limitation of no more than three months of costs requested in order to minimize risk to the University.

What has changed from the previous process?

In response to: (1) Office of the Inspector General (OIG)  repeated audit findings  of high volume of cost transfers onto federal  grant funds at universities across the Country  and, (2) requests from Departments/ORUs to obtain advance spending approval more often and more expeditiously, the UC San Diego campus has determined that the criteria for securing confirmation of funding for pending awards from federal sponsors issuing grants and cooperative agreements should be  expanded  and the process of obtaining such approvals be streamlined. 

What are the risks, liabilities and limitations of the Advance Spending Request?

The risks, liabilities and limitations associated with pre-award spending must be carefully considered prior to requesting authorization to spend funds in advance of receiving an award.

Risks:  Whenever the University authorizes pre-award spending, the University is risking monetary loss. The Federal sponsor is under no obligation to reimburse such costs if for any reason the University does not receive an award or if an award is delayed or is less than anticipated and inadequate to cover such costs.

As such, the PI must identify alternate non-federal, unrestricted funding sources that are available to cover the risk of a delayed start date, costs potentially disallowed by the sponsor, or instances where a sponsor cancels the issuance of an award.

Liabilities:  Special care must be exercised in assessing the impact of pre-award spending on the legal obligations of the University prior to requesting or approving advance spending.  The University must consider the impact of not having a fully executed grant or cooperative agreement on its legal obligations regarding intellectual property rights, subject injury, indemnification, etc.).

Limitations: A sponsor's policies, the terms and conditions of the anticipated award, and campus policies and practices determine whether or not pre-award spending or pre-award activities are allowable. Restrictions differ depending on the funding agency and the type of award anticipated.

Where can I locate the guidelines and the form itself?

How to Submit an Advance Spending Request (PDF)

Advance Spending Request Form (Excel)

These forms are also available from the OCGA Forms page.

Why should an Advance Spending Request be used?

It is not in accordance with OMB Circular A-21 to charge a pending project’s costs to another sponsored project and subsequently transfer these costs after the pending project’s fund/index has been established.  Such a cost transfer can result in penalties and other sanctions applied to the University that could impact the campus’ research enterprise. Establishing the correct fund/index for a project eliminates the audit risk exposure by assigning it from the very beginning. The fund/index number set up via the Advance Spending Request process remains with the award when it arrives.

What research compliance aspects have to be approved in order to proceed with an Advance Spending Request?

Given that establishing a fund/index via an Advance Spending Request is akin to accepting an award, any applicable research compliance matters must be approved/managed (e.g., human and/or animal subjects, conflict of interest, PI Exception, etc.).

What happens if the sponsor does not issue the grant or cooperative agreement or the start date is delayed beyond 90 days pre-award (if such pre-award costs are allowable by a sponsor)?

The rationale for an alternate non-federal unrestricted fund source being included in an Advance Spending Request is to allow for an appropriate source for costs to be transferred to in the instances where an award is ultimately not issued by the sponsor or the start date is delayed beyond 90 calendar days pre-award.

What happens if the sponsor has not issued the grant or cooperative agreement by the end of the Advance Spending Request period?

In the unlikely event that a sponsor has not issued an award by the end date of the initial three month Advance Spending Request or additional funds are needed beyond the amount already requested, a secondary Advance Spending Request should be submitted to the Office of Contract and Grant Administration. The intent of this would be to allow for continued spending on the already established fund/index.  Such a second request would involve a continued financial risk and should be evaluated prudently.

When is an Advance Spending Request not allowable?

An Advance Spending Request is not allowable when:
  1. The effective start date of the project is not until the date of final signature; in such cases spending cannot begin until the award is fully signed.  For example, the majority of federal contracts are structured this way and are not candidates for an Advance Spending Request.
  2. Based upon terms contained in the Request for Proposal, the University informed the sponsor at time of proposal submission that we reserved the right to negotiate terms and conditions of any resulting award.  For example, if the funding announcement included a sample award document which had publication restrictions, intellectual property ownerships issues, and/or export control concerns, etc., such a proposal would not be a candidate for an Advance Spending Request.
  3. There is indication (based on prior experience) that award terms and conditions will conflict with University policy and a protracted negotiation period is likely.  For example, contracts with for-profit industry and certain non-profit foundations are not candidates for an Advance Spending Request.
  4. A sponsor is known to be problematic with award release.  For example, a sponsor that will not issue new awards if there are any outstanding reporting obligations (technical, financial, property, etc.) from an existing award to the University.

Who approves Advance Spending Requests?

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