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FIND A POLICY
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POLICY STATEMENTIf principal investigators want to obtain a project number before the sponsored project is awarded or before it is completely processed, they must establish an advance or preaward account. All costs incurred on an advance or preaward project must meet the same criteria as costs incurred after the award arrives. Department must pay any unfunded costs. In addiiton, principal invetigators must fulfill education and compliance requirements before charging costs. OMB Circular A110 requires grantees to notify the funding agency of developments that have a significant impact on the award-supported activities. The University must also notify them in the case of problems, delays, or adverse conditions which materially impair the ability to meet the objectives of the award. In addition, some sponsors may not approve expenses planned for the future budget period. Before incurring costs not covered in a current statement of work, principal investigators and department administrators must review the agreements carefully to determine whether prior approval is necessary. Sponsored Projects Administration can assist. Federal award under expanded authority typically allow costs to be moved between budget periods without agency approval. However, department remains responsible if continuaions or supplemental awards are not funded. These types of costs should be minimized because the University cannot bill for such costs until official award is made by the agency. Advance Account:Charges incurred prior to the start date of a contract are usually unallowable charges because they are made before the date agreed upon in the final agreement. However sometimes the agreement language is still being negotiated when the anticipated start date of the project arrives. To avoid delaying the research, the principal investigator can request an advance account to begin the project. The charges on this advance account will be allowable because once the agreement is signed, the start date on the agreement will coincide with the effective date of the advance account. Preaward Account:Some sponsors allow charges to be incurred prior to the start date of the agreement. Federal sponsors usually permit charges up to 90 days before the start date and many businesses funding clinical trials allow start-up costs on those projects. In these cases, the principal investigator can request a preaward account. Even though the charges are incurred outside the dates of the final agreement, they are allowable because sponsor policy permits them. In lieu of obtaining a preaward or advance account, it may be allowable to charge the expenses to a department account and transfer them later. However, the expenses must be moved within the cost transfer deadlines. REASON FOR POLICYPrincipal investigators have legitimate reasons for needing preaward or advance accounts, for charging costs on these accounts, and for incurring costs planned for future budget periods. However, these accounts and costs put the University at risk because they may not be covered by sponsored agreements and the sponsors could refuse to pay the costs. This policy outlines internal controls and procedures that ensure accountability over the funds, meet required sponsor regulations, and provide documentation for audits. PROCEDURESFORMS/INSTRUCTIONSADDITIONAL CONTACTS
DEFINITIONS
RESPONSIBILITIES
APPENDICESThere are no appendices for this policy. FREQUENTLY ASKED QUESTIONSThere is no FAQ for this policy. RELATED INFORMATION
HISTORY
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2006 Regents of the University of Minnesota The University of Minnesota is an equal opportunity educator and employer. |