Scope

A Principal Investigator (PI) or Project Director (PD) may request the establishment of a preliminary spending account for a new sponsored project prior to receiving an official Notice of Award (NOA). This account is known as an Advance Account in ResearchUVA (RUVA), and in Workday, it will be designated with an At Risk Preliminary status. These accounts are commonly referred to as at-risk awards and are established for an initial period of six months.

The Office of Sponsored Programs (OSP) will use its discretion on setting up an Advance Account if the NOA is received and ready to be set up in RUVA and Workday.

During the award's period of performance, a PI or PD may request an extension of the award beyond the current end date, before receiving sponsor approval of the extension through an official NOA or a fully executed contract amendment. This process is known as an Advance Account Extension or an at-risk extension. An Advance Account Extension can be requested for up to six months past the award end date. In RUVA, the award will remain active, and in Workday, the status will change to Pending Sponsor Extension.

Definitions

Advance Account are awards set up in RUVA and Workday prior to the receipt of the sponsor's NOA, allowing the initiation of a new with assurance from the sponsor that the award is forthcoming.

Advance Account Extensions are continuations of existing programs beyond the authorized period of performance end date, permitting work to proceed on the project while awaiting an official sponsor extension.

Responsibility

The PI or PD is responsible for:

  • Initiating and authorizing the request for establishment of an Advance Account or an Advance Account Extension. 

The Department Chair is responsible for:

  • Approving or denying the Advance Account request, thereby assuming the financial responsiblity of the department in the event that funds are not forthcoming. 

School/Departmental Administrators are responsible for:

  • Preparing and submitting the Send Grants Status Update to OSP.
  • Providing the appropriate approvals and any supporting documentation (e.g., email from sponsor, etc.).
  • Identifying the award type (i.e., fixed price or cost reimbursable) with the request
  • Reviewing and confirming the Advance Account setup in the financial system. 

OSP is responsible for:

  • Reviewing the Advance Account request for completeness.
  • Ensuring the project meets relevant compliance requirements.
  • Advising on the risk associated with the Advance Account setup.
  • Establishing Advance Account awards within the terms of this procedure and all other applicable rules and regulations pertaining to sponsored programs administration.

Procedure

Requesting an Advance Account

Advance Account requests must be submitted using the Send Grants Status activity or Email Status activity from the proposal in RUVA

Advance Account Requests must include the following information:

  1. Identifying information:
    1. Related Funding Proposal ID,
    2. PI name,
    3. Sponsor(s) name(s), and
    4. Fixed price or cost reimbursable contract type, if known.
  2. Requested start date.
  3. Sponsor assurance of forthcoming award or draft agreement. 
  4. School approvals, consisting of signed approval or acknowledgment in writing or email, from the following:
    1. The PI or PD,
    2. The Department Chair, and
    3. An authorized school representative.
  5. School- or unit-specific Advance Account request form, if applicable. 
  6. A non-sponsored account for assurance in case the award is not funded or expenses need to be moved. 
  7. Regulatory approvals, such as human subjects or animal use, or compliance approvals, suc as export controls. 
    1. If IRB or IACUC approvals will be delayed, the Advance Account request must also include a certification from the PI or PD that no human subjects and/or animal research will occur prior to receiving the necessary approvals. 
    2. OSP will review any draft materials to ensure that there is no restriction on the release or use of funding prior to approval. 
  8. It is best practice to include certification that all Key Personnel/Investigators have completed their compliance requirements, as this will stop the Advance Account setup.

Once the request is submitted to OSP for review, OSP will:

  1. Confirm compliance with all compliance requirements for time-of-award,
  2. Review the NOA for complance and material risks of inability to reach a final agreement with the sponsor on issues like publication, intellectual property, and data rights. 
  3. Expedite review and establisment of Advance Account awards. 

Sponsor Assurance for Advance Account Requests

Advance Account requests should not be submitted to OSP unless funding by a sponsor is assured. Although written verification from the sponsor of a pending award is not required, it is prudent to have some written indication of the anticipated award start date. For example:

  • Incoming subaward: Documentation that the prime award was received by the Pass-Through-Entity (PTE).
  • Industry sponsored award: Draft agreement received by the sponsor.
  • Foundation or non-profit award: Any written intent to fund or offer acknowledgment requests.
  • Federal award: A federally sponsored Advance Account request must be made within the 90-day preaward period of the anticipated start date and include either a written intent to fund notice from an authorized official, a documented score within a fundable range, or a request for Just-in-Time materials.

Start Date Considerations

For a federal grant or cooperative agreement, the start date determines the allowable 90-day preaward period. In the case of a federal contract, preaward spending may not be permitted. The start date requested with the Advance Account award needs to be as accurate as possible. In determining the start date consider:

  • Incoming subaward: With federal flow-through funding on a grant or cooperative agreement, the subawardee is allowed the same 90-day prea-ward spending as the PTE.
  • Non-federal: A non-federal sponsor may use language in the agreement stating that the Period of Performance (PoP) begins “upon execution” of the contract. OSP typically advises against the set up an Advance Account award with this language. Exceptions may include:
    • The sponsor provides written documentation of authorized pre-award spending,
    • The sponsor agrees to define a specific start date of the PoP,
    • The sponsor accepts redlines to the agreement and the addition of a start date, or
    • Clinical trial agreements wherein study start-up costs are not necessarily tied to the period of performance.
  • Federal: Pre-award costs on federal grants or cooperative agreements are typically limited to 90 days prior to the sponsor's start date. If there is a delay in the anticipated start date, costs may not be allowed under preaward authority. It is the responsibility of the department to remove all unallowable charges from the award.

Note, some sponsors provide an “Authorization to Proceed” that authorizes UVA to begin work on a project during negotiation of the NOA. In those situations, OSP sets up an active account and will invoice the sponsor.

Extensions of an Advance Account

If the award has not been received during the initial six-month period, the PI/PD may request an extension of the Advance Account. The Advance Account may be extended for an additional six-month period upon request and with approval of the Department Chair. Department Chairs are encouraged to take into consideration any written assurances of an award from the sponsor when approving an extension. Extensions beyond 12 months require the approval of the Assistant Vice President for Research Operations, Compliance & Policy.

Activating or Closing an Advance Account

In the event a project is not funded, the original department is responsible for the expenditures incurred. Similarly, the department is responsible for any expenditures not approved by the sponsor or in excess of the amount of the award. In cases where there is a change of start date and pre-award expenditures are not allowed, the department will be responsible for moving any expenditures prior to the contractual start date on to a non-sponsored worktag.

Since Advance Accounts are not entered with funding or budgets in the financial system, they will appear as overdrawn in all budget-to-actuals reports where expenses are compared against budgets. If an award is not received by the end of the Advance Account period, OSP Post Award will work with the department to move the costs to a non-sponsored account. The department's F&A worktag is the guaranteeing fund for Advance Accounts, and costs will be transferred to a departmental F&A worktag if no other F&A or local worktag is provided to OSP.

Requesting an Extension on an Existing Active Award

Advance Account Extension requests are to be made using the Award Modification Request activity from the Award record in RUVA. 

Advance Account Extension requests must include the following information:

  1. Requested end date
    1. An Advance Account can be extended up to a maximum of 6-months. Indicate if you will need a shorter extension period. 
    2. Clincial trials with no set end date in the agreement are extended without being considered at-risk. These would be requested as a No-Cost Extension (NCE). 
  2. Sponsor assurance of the imminent award amendment and type of the anticipated award (e.g., NCE or incremental funding).
  3. School approval, consisting of signed approval or acknowledgment in writing or email, from the following:
    1. The PI or PD,
    2. The Department Chair, and
    3. The appropriate school representative. 
  4. School- or unit-specific Advance Account request form, if applicable.
  5. Regulatory approvals, such as human subjects or animal use.
  6. Indication if there will be new personnel on the project, including certification that all Investigators have completed their compliance requirements as this will stop the Advance Account Extension. 

Once the request is submitted to OSP for review, OSP will:

  1. Confirm compliance with all compliance requirements.
  2. Review, if applicable, the agreement amendment for compliance and material risks of inability to reach a final agreement with the sponsor on issues like publication, intellectual property, and data rights. 
  3. Expedite review and establishment of the Advance Award Extension.

The Advance Account Extension will cease to be at-risk once funding has been received from the sponsor, and, if applicable, the sponsor agreement is fully executed. If there is funding, it will be loaded to the award, the award end date will be updated, and the award will no longer be considered in an at-risk status.

Ownership

The Executive Director of the Office of Sponsored Programs is responsible for ensuring that this procedure is necessary, reflects actual practice, and supports University policy. 

Related Policy

RES-009: Solicitation, Clearance, Acceptance, and Ongoing Management of Sponsored Programs