Spending at Risk: Pre-award Spending and Preliminary (Early Setup) Budgets

Notwithstanding the problems that might result from spending funds from an award before a final agreement is executed, it is possible to request authorization for pre-award spending on grants and cooperative agreements with many federal agencies and to charge award-related expenses up to 90 days prior to the award start date. See APM 45.05 for additional information.

The department or college can also request to establish a preliminary (early) setup in advance of the official agency award receipt or review and acceptance. It is necessary to complete an early setup request form in VERAS for this. The rules on these requests are as follows:

• Any required compliance protocols or assurances must be in place before the accounting can be released.
• You will be requested to provide the anticipated start date. Agreements with Industry sponsors and Foreign Entities (including Canada) are generally not allowable for early setups due to state limitations on using appropriate funds for industry support, and a history of problematic terms and conditions (foreign). Project agreements and sponsors that typically utilize terms with start date as "date of last signature" are ineligible for early setups; OSP processes these agreements as a rush.
• If the early setup is not eligible for a VPRED guarantee, a guaranteed index number is required in addition to Chair and Dean signatures. The Post Award team will route your early setup request form for Chair/Dean approvals if the project is not VPRED eligible.
• Standard procedure is to set up the early setup index for 25% of the first increment of funding and for 90 days from the start date. Other dollar amounts and time frames must be requested in the form and will be evaluated by the Office of Sponsored Programs.

If the award is ultimately not made, is made for a lower amount, or the expenses fall outside of the start date or 90-day pre-award period, the department will be responsible for any unallowable charges.