UVA Financial & Administrative Procedure

Procedure: 8-12	Effective: July 1, 2001
Owner: Assistant Vice President for Research Administration	Latest Revision: May 8, 2007

Request to Establish or Extend Awards Prior to Receipt of Funding
(“At-Risk” Awards)

Scope

This procedure sets out the process whereby a Principal Investigator/Project Director (PI/PD) may request the establishment of a preliminary PTAO, known as an At-Risk award, pending official notification from the sponsor.
At-Risk awards are established at the request/direction of the PI/PD and with the approval of the appropriate Department Chair. By approving the request, the Chair is obligating the department to cover all expenses charged to the At-Risk award should the sponsor not make the award or disallow any of the costs incurred.

At-Risk awards are requested using an SP-23 form. At the direction of the PI/PD, this form is used to request the establishment of a temporary account to allow (1) the initiation of a new program when funding has been assured by a sponsor, but official award documents have not yet been received or (2) continuance of an existing program when funding has been assured by a sponsor, but official award documents have not yet been received (referred to as an At-Risk extension).

NOTE: At-Risk award requests should not be submitted unless subsequent 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 federal sponsors the start date determines the allowable 90-day pre-award period, when applicable. In the event a project is not funded, the originating 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.

System References [Top]

At-Risk Account Request Form (SP-23)
Available at the OSP website
Blank forms are also available from Research Administrators or from the Office of Sponsored Programs, Carruthers Hall, 434-924-4270
Forward completed form (original only) to the Office of Sponsored Programs for processing and subsequent approval.

Policy [Top]

Grants and Contracts: Documents to be Approved by the Office of Sponsored Programs -- Policy VIII.A.4

Responsibility [Top]

The Principal Investigator/Project Director
The Principal Investigator is responsible for initiating and authorizing the request for establishment of an At-Risk award.

The Department Chair
The Department Chair is responsible for approving or denying the At-Risk request, thereby assuming the financial responsibility of the Department in the event that funds are not forthcoming.

School/Departmental Administrators
The School/Department administrator is responsible for preparation and submission of the SP-23 form to the Office of Sponsored Programs, including the provision of appropriate signatures and approvals, as well as any supporting documentation (e.g. email from sponsor, etc.).

Office of Sponsored Programs
OSP is responsible for reviewing SP-23 forms for completeness and establishing At-Risk awards within the terms of this procedure and all other applicable rules and regulations pertaining to sponsored programs administration.

Distribution [Top]

Principal Investigator/Program Director
Grants Administrator – Department/School
Grants Administrator – Office of Sponsored Programs

Ownership [Top]

The Assistant Vice President for Research Administration is responsible for ensuring that this procedure is necessary, reflects actual practice, and supports University policy.

Definitions [Top]

At-Risk Awards are PTAOs set up in the Integrated System prior to the receipt of the sponsor’s notice of award to allow the initiation of a new program or the continuance of an existing program when funding has been assured by a sponsor. This term refers to what used to be known as a “preliminary” account.

SP-23 Forms are completed by the School/Departmental administrator in collaboration with the principal investigator. These forms are available from the Office of Sponsored Programs website.

Procedure [Top]

AT-RISK AWARD:

At Risk awards will be established for an initial six month period.

If the award has not been received during the initial period, the principal investigator may request an extension of the At-Risk award. At-Risk awards may be extended for an additional ninety (90) days upon request and with approval of the Department Chair and appropriate School official. Department Chairs and School officials are encouraged to take into consideration any written assurances of an award from the sponsor when approving an extension. Extensions beyond this point require the approval of the Assistant Vice President for Research Administration.

At-Risk awards will appear on deficit reports since no budget is loaded. At-Risk awards will automatically appear on notices sent to department chairs after they have been in deficit for three months. These deficits will not be charged to departmental F&A accounts while the At-Risk award is active. If no award is received and the At-Risk award has ended, OSP will contact the award-owning Department for instructions as to what local or F&A award should cover the costs. The Department’s F&A award is the guaranteeing fund for At-Risk awards and costs will be transferred to a departmental F&A PTAO if no other F&A or local PTAO is provided to OSP.

NOTE: Pre-Award costs on federal awards are typically limited to 90 days prior to the sponsor’s start date (see note above). If there is a delay in the anticipated start date, costs may not be allowed under pre-award authority. It is the responsibility of the Department to remove all unallowable charges from the award. If correcting action is not taken in a timely manner, OSP will facilitate action through the
deficit notification process.

HOW TO REQUEST AN AT RISK AWARD:

1. At-Risk PTAO requests are to be made using the SP23 form. The form should be fully completed.

2. Department Chairs or School officials may require that At-Risk PTAO requests include a specific budget amount. In those cases departments have the responsibility of ensuring that expenditures do not exceed the approved budget.

NOTE: The School of Medicine requires that maxium total budget amounts be included as part of the At-Risk PTAO request.

3. If information concerning the pending award has been received, from the sponsor, briefly
summarize the message on the SP-23 or attach supporting documentation.

4. Additional justification for extensions over nine months should be included in the request, via or attached to the SP-23 form.

5. At-Risk Award requests must be approved and signed by (1) the PI/PD (2) the department chair, and (3) the appropriate school representative. The College of Arts & Sciences does not require that At-Risk requests be approved by the School for those departments having a Research Administrator. All other A&S departments and other Schools require approval through the School’s research administration office.

7. Once completed, original forms should be submitted to the Office of Sponsored Programs for processing. OSP commits to an expedited review and establishment of At-Risk accounts.

8. The At-Risk award will cease to be at risk once funding has been received from the sponsor. The sponsor budget will be loaded to the established At-Risk award, and the award will then no longer be considered “at-risk.”

End of Activity