Spending at Risk: Pre-Award Spending and Early Set-Up Budgets
Notwithstanding the problems that might result from spending funds from an award before a final agreement is executed, it is possible, under A-110 “Expanded Authority,” 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.
To set up a preliminary budget in advance of the official agency award it is necessary to complete a Preliminary Budget Request Form, and to provide a guarantee budget in the event that the award is not received. The rules on these requests are as follows:
- Any required compliance protocols or assurances must be in place;
- if possible provide the anticipated start date (note that agencies that issue contracts or agreements effective on the date of final signature are not eligible for early set-up);
- a guarantee budget in the event that the funding does not come through must be provided and the person responsible for the guarantee budget must sign his or her approval for the guarantee;
- the budget will be set up for a maximum of $10,000 or half of the anticipated award, whichever is less, and for 90 days from the start date. Other amounts/times must be negotiated with OSP.
If the award is ultimately not made, is made for a lower amount, or the start date is beyond the 90-day pre-award period, the department will be responsible for any unallowable charges.