‘Advance Projects’ are a mechanism to provide Principal Investigators (PIs) of direct federally funded grant awards with the opportunity to initiate research, hire staff and incur project-related expenses up to 90 days prior the official time period of the project.
‘Advance Projects’ can be set up only for direct federal awards.
‘Advance Projects’ do not apply to:
- Federal Pass-through (awards funded from a federal source via a pass-through award to another organization);
- Awards funded from a non-federal source;
- Federal or non-federal contracts;
- Training grants or fellowships;
Expenses for subawards are not permitted as part of an Advance Project.
‘Advance Projects’ can be set up for up to 90 days prior the time period of the direct federal award.
4. Individual Project Spending Limits
4.1 Initial Spending Limit
Expenditures in ‘Advance Projects’ are initially limited to $25,000.
4.2 Additional Spending Limit (s)
Once the spending limit is reached, the PI may apply for a higher spending limit(s). Any advance-disallowances that exceed the initial limit must be covered by sources other than the Sponsored Programs Reserve. Therefore, when requesting an additional limit, the PI must clearly identify the funding source that any potential advance-disallowances will be covered from. The approval of the additional limit is subject to approval of the owner of the alternate funding source, and the respective Dean of the College, or the Provost.
5. Unallowable Costs/Advance-Disallowances
5.1 Pre-Award Costs
Pre-award costs are those incurred prior to the effective date of the Federal award directly pursuant to the negotiation and in anticipation of the Federal award where such costs are necessary for efficient and timely performance of the scope of wor. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award... (CFR $200.458)
5.2 Unallowable Costs
Unallowable Costs are all costs that have been spent on behalf of a project, but have been determined not to be allowable as part of the project. Reasons for being determined unallowable may be, but are not limited to:
- Costs have not been incurred within the project period
- Costs are not reasonable
- Costs are not part of or allocable to the project
Allowability of costs in federally funded projects is detailed in the “Uniform Guidance Subpart E – Cost Principles” (http://www.ecfr.gov/cgi-bin/text-idx?SID=ed90f54836feb6a994f657188eb05e33&node=2:18.104.22.168.1&rgn=div5#sp2.1.200.e ). Should you have any questions, please contact your liaison for advice and interpretation.
Advance-Disallowances are those unallawable costs that are specifically due to a direct federal award issued after the intended start date or not at all,.
5.4 Coverage of Advance-Disallowances
In the event that, despite expectations, a direct federal award is issued after the intended start date or not at all, the resulting advance-disallowances will be covered by the Sponsored Programs Reserve for up to the amount of the initial spending limit of $25,000 for the ‘Advance Project’. This coverage through the Sponsored Programs Reserve does not apply to any unallowable costs other than the advance-disallowances.
5.5 Coverage of Additional Spending Limits and Other Unallowable Costs
It is the responsibility of the PI to identify alternative funding sources for advance-disallowances exceeding the initial spending limit of $25,000 and all other unallowable costs.
6.1 Set-up of ‘Advance Project’
a) The PI will request the set-up of an ‘Advance Project’ via email to the Office of Research and Sponsored Projects (ORSP); (see attachment)
b) The PI will provide/initiate verification from the granting agency to ORSP that the award will be forthcoming. If possible, a copy of the unsigned agreement should be requested. An email from granting agency will be considered as sufficient evidence; ORSP may assist the PI by contacting the granting agency;
c) The Director of Research & Sponsored Projects at ORSP will approve the set-up of an ‘Advance Project” and will provide the following information to The University Corporation-Sponsored Programs (TUC-SP):
· Principal Investigator
· Project title
· Granting agency
· Total award amount
· Project period
d) TUC-SP will set up the ‘Advance Project’ in PeopleSoft including a $25,000 budget amount, issue a Project ID and notify the Principal Investigator, the Manager of Academic Resources (MAR), and ORSP;
e) TUC-SP will allow expenditures to the ‘Advance Project’ up to the funding limit.
6.2 Arrival of the Award
Once the final award is issued, TUC-SP will update the information in PeopleSoft, thereby converting the ‘Advance Project’ into a regular project.
6.3 Treatment of Advance-Disallowances
TUC-SP will transfer any advance-disallowances resulting from an award issued with a start date after the planned start date to the Sponsored Programs Reserve up to the $25,000 spending limit of the ‘Advance Project’.
TUC-SP will continuously monitor all ‘Advance Project’ and advance-disallowances via the ‘Project Tracker’ system.
7. Employment Clause
All employment contracts funded from an ‘Advance Project’ must contain the following condition: “This employment relationship is entered into in anticipation of a grant award. Employment is contingent on the actual execution of the funding of the award”.
8. Total Program Ceiling
The maximum annual amount for advance-disallowances covered from the Sponsored Programs Reserve during a Fiscal Year is $50,000. If the sum of all advance-disallowances within in a Fiscal Year exeed the threshold amount, all spending from all current Advance Projects is halted and no new Advance Projects will be approved. Exceptions for expenses for personnel cost from employment relationships already entered into, may apply.
9. Regulated Activities
Principal Investigators must certify that Advance Projects either will not involve any activities that require regulatory review and approval (Institutional Review Board (IRB), Instituional Animal Care and Use Committee (IACUC), use of regulated materials, etc.), or that any such approvals have already been obtained at the time of application for an Advance Project.
This procedure is valid as of Oct. 1, 2016