Pre-award costs are those incurred prior to the effective date of the l award directly pursuant to the negotiation and in anticipation of the award where such costs are necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the award and only with the written approval of the awarding agency.
If the expected award segment is not received in full, or if the sponsor does not approve the incurred pre-award/advance expenditures, the PI's department/school/college is responsible for any un-reimbursed expenses.
According to Uniform Guidance Section 200.308(d)(1), grantees can approve costs incurred 90 calendar days prior to the award start date, or more than 90 calendar days with the prior approval of the Federal awarding agency; however, the grantee engages in pre-award (or advance) spending at its own risk. The Federal sponsor is under no obligation to reimburse such costs if, for any reason, the grantee does not receive an award, the award is not continued, or the award is less than anticipated and inadequate to cover the pre-award (or advance) spending. The NIH Grants Policy Statement states: “The incurrence of pre-award costs in anticipation of a competing or non-competing award imposes no obligation on NIH either to make the award or to increase the amount of the approved budget if an award is made for less than the amount anticipated and is inadequate to cover the pre-award costs incurred.”
Howard University receives sponsored program awards from a wide variety of sponsors. Sponsors have their own guidelines regarding pre-award (and advance) spending. These guidelines may limit the range of possibilities available to Howard University. In all cases, Howard University's position regarding any particular request for pre-award spending is subject to the limits imposed by the policies and guidelines of the sponsoring agency. As well as Howard University.
Please see Pre-Award/Advance Spending Policy 600-008