Guidelines for Grant and Contract Management
401. Account Creates
Account Creates Stemming from Notice of Award Actions
The Local Business Centers (LBCs), BSD Dean’s Office, Medicine, BMB, Ben May, Pathology, Cancer Research Center and CALGB will create or update Financial Accounting System (FAS) accounts for awards that they manage upon their receipt of the award from URA. Similarly, the Restricted Funds (RF) Section of the Comptroller’s Office will create or update accounts for all other awards upon RF’s receipt of the award notice from URA. RF will enter account administrators and authorized signers for the award based upon the past practices of the administering department. If those assumptions are incorrect, the department must instruct RF how to modify that information. A department does not need to transmit a Form 70 to RF.
Advance Accounts
Except for pharmaceutical and other nonfederal sponsored clinical trials, FAS accounts may be created in advance of the receipt of a notice of award. The University refers to these accounts as advance accounts. Departments are encouraged to create advance accounts if oversight committees have approved any protocols that would apply to costs that would be charged to the advance account, the likelihood of the award is high, and allowable startup costs need to be incurred. Also, in some cases, costs may not need to be incurred prior to the start date of the award, but an account number is nevertheless needed in advance in order to ensure that payroll, recharge center and other billings are recorded timely once the award does begin. Using an advance account will help the startup of the sponsored project and eliminate the need to make cost transfers at a later date. There are, however, risks with incurring costs in advance of receiving the award.
Starting project expenditures before the University has concluded award negotiations with an award agency weakens the University’s and strengthens the awarding agency’s negotiating position.
If a notice of award has an award begin date that is later than what was expected when its advance account was created, then expenses incurred earlier than the award’s allowable pre-award period would be unallowable unless approval was sought and received from the awarding agency. For example: Assume that a department requested an advance account for an NIH R01 award it expected would begin April 1. Because NIH awards have an allowable pre-award expense period of 90 days, the department requested an advance account begin date (i.e., the date on which advance account expenses could first be incurred) of January 1. Now assume that NIH issues the notice of award with a May 1, award begin date. What are the ramifications of the begin date being May 1 instead of April 1? It means that any expenses incurred prior to February 1 were outside of NIH’s 90 day allowable pre-award period and, therefore, the department would have to remove those expenses from the account or request and receive approval from NIH to charge them to the award.
A more critical risk is that the award is not received at all. In that case, as in any case when a cost is disallowed, the department is responsible for funding the costs.
The LBCs, BSD Dean’s Office, Medicine, BMB, Ben May, Pathology, Cancer Research Center and CALGB can create advance accounts for awards they administer. All other departments must request advance accounts through RF by completing a Form 70B and emailing it directly to the Post Award Administrator in RF responsible for the requesting unit. Note that some units, such as BSD, may have additional procedures and guidelines related to advance accounts that must be adhered to.
Additional Account Creates
Accounts in addition to the accounts created at the time of the award notice may also be created. Additional accounts may be required to accommodate off-campus location expenditures, voluntary committed or mandatory cost sharing not identified at the time the initial accounts were created, or for other award management purposes. Request the accounts through the same unit that created the accounts upon receipt of the award notice. Requests through RF should be made by transmitting an email to the Post Award Administrator in RF responsible for the requesting unit. The email should identify the reason for the request, the award’s master account, and attribute values for the requested associate if they differ from the master account attribute values, and budgeting instructions.
Questions regarding account create procedures should be directed to Pat Hallow, Manager of Post Award Administration, or Casey Murray, Associate Comptroller.
