Generally, spending on a sponsored project should not begin until an award is received and accepted by the University. In certain circumstances, pre-award expenses (spending in advance of the award) may be incurred to ensure the efficient and timely performance of the scope of work, provided that the expenses are necessary for the performance of the project and are allowable under the terms of the award. In such cases, Principal Investigators (PIs) may request approval for pre-award spending. If you need to spend prior to the 90-day pre-award, or other period allowable under the award, you must contact your pre-award office (i.e. ORA/ORS) to initiate a prior approval request to the sponsor, before any charges are incurred. Documentation of the sponsor’s approval of an exceptional pre-award window must be retained with the award documents in a Duke institutional system.
Pre-award code requests for industry supported research
For School of Medicine and School of Nursing industry supported research, pre-award code requests go through the Office of Research Contracts (ORC) by submitting a pre-award code request in SPS. An explanation, draft contract, draft budget, and current version of the protocol need to be included in the request.
Note: pre-award codes can be requested prior to the clinical trial agreement being routed for signatures. If the agreement has already been routed for signature, a pre-award code cannot be requested.
Pre-award spending for federally sponsored awards/contracts or foundation awards
Pre-award spending occurs at Duke’s risk until the official award notification is received and the terms of the award accepted by the University. Therefore, before pre-award spending may occur, the PI must have prior institutional approval. In some cases, written sponsor approval may be required for pre-award spending prior to incurring any costs. Most Federal sponsors allow pre-award spending up to ninety (90) calendar days before the start date of the agreement budget year subject to their guidelines and terms of the award.
If pre-award costs are allowed by the sponsor and approved by the institution, appropriate expenses can be charged to the designated pre-award fund code (WBSE) in advance of the award. The sponsor is under no obligation to reimburse such costs if for any reason the University does not receive an award, if the award is delayed or if the award is less than anticipated or not adequate to cover the pre-award expenditures. The owning organization of the anticipated award must accept the pre-award spending risk and provide backstop funds in the event that the anticipated award does not materialize as expected.
- For Campus Schools and Provost Area: Grant managers should email email@example.com to request pre-award spending
- For Schools of Medicine and Nursing: Requests for pre-award spending on federally sponsored awards or foundation awards are submitted by grant managers using the Submit a Request feature in myRESEARCHhome.
Risks, liabilities, and limitations
Any time project costs are incurred in advance of an award, the University (PI/owning org) assumes the financial risk if the University does not receive an award, if there is a prolonged delay in the receipt of the award or if the award is less than anticipated or not adequate to cover the pre-award expenditures.
It is the responsibility of the PI/owning org to ensure other non-sponsored funding is available to cover the risk of a delayed start date, costs disallowed by the sponsor or failure of the sponsor to make an award as anticipated. It is the PI’s responsibility to take the appropriate steps to ensure minimal risk of pre-award spending to the institution.
The University must consider the impact of not having a notice of award or fully executed agreement in relation to the project activities to be undertaken. Some project activities must have a formal agreement in place before the work can commence.
In all cases, the University requires notification from the sponsor in the form of an email, Just-in-Time (JIT) request or other written documentation that supports the likelihood the project will be funded.
The sponsor's policies, the type of award anticipated (grant, contract or cooperative agreement), the terms and conditions of the anticipated award, other Federal regulations (e.g., Uniform Guidance) and the interests of the University determine whether or not pre-award spending or pre-award activities are allowable.