Advance Budget Numbers: Revised Criteria for Eligibility

Presented by: OSPJune 13, 2013

What is an Advance Budget?

• A request for authorization to spend a limited amount of money during a specified period prior to the receipt of an executed award from the funding agency.

• The department is responsible for any pre-award costs that are subsequently not allowed by the sponsor.

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When to Request Advance Budget Number?

• To support pre-award spending when allowed by the sponsor.

• When the award is delayed:– Not been received in OSP by the effective date of

the award.– Negotiation or processing of the award is not

complete.

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Advance Budget Request

• Department completes the Eligibility Form• Eligibility Form auto-emails to OSP• If OSP confirms eligibility then “hold flag” is

removed• Department completes Advance Budget

Request (ABR) in SAGE• ABR sent to GCA for processing• GCA send an email to Department with

budget number

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You Asked for It!

• Campus requested the ability to document and acknowledge the fiscal risk with incurring pre-award costs in order to receive an advance budget numbers more quickly and easily.

• Campus requested the ability to attach documents.

• The Advance Budget Number Eligibility Form has been modified as a result.

Department Acknowledges Risk in Eligibility Tool

• Department provides an alternative budget number.

• Department assumes responsibility for pre-award expenditures if the award:– Is not issued– Is issued, but pre-award spending is disallowed by

the sponsor• The Risk Assessment is explained in both the

new ABR Primer and in the Eligibility Tool.

Reasons for Change

• Department wants lead time to do administrative set-up under the parent Advance BN.

• Sponsored program continuity on projects in which sponsor is consistently late with the renewal funding, does allow these costs, but does not formally recognize pre-award spending.

• Consistency with the Dept. Chair or Dean sign-off on the GCA ABR form.

A Look Into the World of OSP

• What does OSP do with the Eligibility Form when they receive it?

OSP Regulatory Compliance Review• Eligibility Form asks compliance questions and

makes request ineligible automatically, depending on answers provided.

• OSP checks 3 compliance areas– Animal Use approval – Significant Financial Interest review complete– Human Subjects approval (IRB approval or

administrative determination)• OSP will contact the Dept. with questions.

ModifiedModified

SFI Compliance Check

Disclosure Status “pending” – there are now 2 possible paths

1. Expedited review by the Institutional Official (IO) (OSP will notify the Office of Research) - OR-

2. With PI written assurance that Investigators named with pending SFI disclosures will not participate during Advance Budget Number stage, the IO may provide eligibility despite pending SFI disclosures.

Human Subjects Compliance Check

• A DOHR is a determination issued by the Human Subjects Division, when DOHR circumstances apply to the project.

• DOHR – Delayed Onset Human Research is now included in the Eligibility Form as an option.

• DOHR Determination allows eligibility to obtain an Advance Budget Number in order to incur non-human subject research expenditures.

• Charging human subjects research expenditures, at any stage, requires an active IRB approval or exempt determination!

Recap

• Form Modified• Department can now document and

acknowledge all financial risk• Now able to attach documents• OSP still does 3 compliance checks• If regulation requires it, we require it

Where do you go to access the Advance Budget Number Eligibility Request Tool?

http://www.washington.edu/research/index.php?page=advanceBudget