The White House’s Uniform Guidance sets forth standards for obtaining consistency and uniformity among federal agencies in the administration of grants to, and agreements with, institutions of higher education. Under “expanded authorities,” many federal agencies have transferred the authority to unilaterally approve a number of pre-award and post-award actions. The following guidelines have been developed to assist Principal Investigators in preparing requests for prior approval actions on Federally-funded grants.
Use the IPAS to:
- Request authorization to incur pre-award costs up to 90 days prior to the anticipated start date of the award as sponsor terms and conditions and federal expanded authorities guidelines permit.
or
- Request authorization for creation of an advance fund if the award is imminent but delayed beyond the anticipated start date.
Requests for prior approval of “pre-award costs, or requests for “advance funding” are at the grantee’s risk, and must be well justified programmatically (and not for mere convenience). Anticipated costs must be reasonable and allowable.
Requests for prior approval are accompanied by a completed Institutional Prior Approval System (IPAS) form signed by the Principal Investigator/Project Director, Department Chair, and Dean. Sufficient supporting documentation from the sponsoring agency/entity of a pending award must be provided along with the sponsor’s concurrence of the anticipated/expected start date of the project. Electronic (e.g., e-mail) correspondence is typically sufficient and may be attached as supporting documentation to the IPAS form.
Upon completion, the form is forwarded to the Office of Sponsored Programs. The Director of Sponsored Programs will review the request for adequacy and completeness and approve the request for processing with the Office of Grant Accounting.
If the award does not materialize for any reason, the Provost will confer with the appropriate Dean(s) and/or Department Chair(s) to determine how incurred costs will be allocated. Should the Director of Sponsored Programs not approve the request, the request may be unilaterally approved by the Dean of the Principal Investigator’s affiliated college. Should the award not materialize for any reason, the Dean will be responsible for 100% of incurred costs.
Note: If the project involves the use of human and/or animal subjects, IRB and/or IACUC approval *must* be in place before prior approval, or an advance fund can be set up, and work can begin on the project.
If you have any questions about the IPAS, or completing the attached form, please feel free to contact OSP at osp@liashapiro.com or 973-655-4128.