Pre-award expenditures (also called pre-award costs) are those incurred prior to the effective date of the award. These costs must be necessary for efficient and timely performance of the scope of work. For Federal awards, pre-award expenditures are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. (2 CFR § 200.458)
A pre-award expenditure request in GMAS is a request that is asking to spend funds up to a maximum of ninety (90) calendar days prior the actual start date of an award. This request should be entered in GMAS for any project where you wish to spend funds before the award start date even if sponsor prior approval is not required.
Pre-award expenditure requests in GMAS are also used to ask to spend funds remaining from a previously awarded budget period in a future budget period. This request only needs to be entered in GMAS for those awards that require sponsor approval to spend funds across budget periods.
Sponsor Approval for Pre-award Expenditures
Federal Grants Under Uniform Guidance
The Uniform Guidance provides flexibility to institutions in the administration of grants. Federal agencies are authorized, at their option, to waive costs related and administrative prior written approvals. Pre-award expenditures that are less than ninety (90) days prior to the start of the award are allowed by most federal agencies and do not require sponsor approval, however these do require University approval.
All Other Awards
Awards that are not subject to the Uniform Guidance require sponsor prior approval for pre-award expenditures.
Requesting Pre-award Expenditures
To request pre-award expenditures in GMAS, from the segment home page, select “Actions” and then “Create request”. Follow the prompts to enter the required information before locking and routing.
- The award notice or agreement which lists the actual start date of the project.
- The dates for the period during which you are requesting pre-award expenditures.
- The dollar amount of pre-award expenditures you are requesting.
- Any other information as required by the sponsor, department or university.
Responsibility for Pre-Award Expenditure Requests
- The department holds primary responsibility for entering information in GMAS to formally request pre-award expenditures.
- The OSP Awards Management team will review the pre-award expenditure request once all required signatures are obtained on the GMAS request.
- The OSP Award Management team will reach out to the sponsor to request prior approval for the pre-award expenditures if required.
- When the sponsor approves pre-award expenditures, the OSP Operations team initiates a revision on the GMAS account.
- The OSP Awards Management team reviews and commits the revision to the account, generating an action memo that is sent to those listed on the Administrative team in GMAS