OSP Prior Approval Requests

The George Washington University (GW), as the grantee, is offered expanded authority by certain sponsors to provide prior approval of specific requests. Additionally, under specific circumstances, GW allows the establishment of at-risk advance awards. In these instances, the Office of Sponsored Projects (OSP) acts in the role of final reviewer and approver of requests.

An Administrative Establishment, also called an At-Risk Advance Account, is set up when a PI needs to commence project activities and incur expenses prior to receipt of the fully executed agreement. A PI may request an Advance Account setup or an extension of an existing Advance Account if the following conditions exist:

A proposal package has been routed through myReserach and submitted to the sponsor.
The award is delayed with the sponsor but a confirmation is received from the sponsor that the proposal will be funded.
The award is in final negotiation and acceptance stage.

Since the department of the PI absorbs unrecoverable costs if an award does not materialize, Advance Accounts require the approval of the Department Chair and Finance Director. These requests should include correspondence from the sponsor communicating both the intent to fund the project and the anticipated start date (not required for awards currently under negotiation).

An Administrative Funding or At-Risk Advance Funding allows a PI to continue research activities and incur expenses in instances when a multi-year award is pending final modification negotiation or additional incremental funding. During the administrative funding request, an active award is placed at risk to allow expenditures to post during the requested period.

Since the department of the PI absorbs unrecoverable costs if an award modification does not materialize, all At-Risk accounts require the approval of department chair and finance director.

Not all budget revisions require sponsor approval. Requests for internal budget revisions can be discussed with the department Research Support Team(RST). The OSP staff will also be able to provide guidance if a revision requires only OSP approval.

The following will be considered:

the approved intent of the project,
how the budget revisions(s) will support the goals of the project; and
if the revision is reasonable, allocable, and allowable.

Cost sharing is an institution’s contribution to the total cost of a sponsored project. It impacts the institutional dollars available for research and the F&A cost recovery and must be approved by the OSP leadership.

Most cost sharing requests are managed and approved prior to the proposal submission. (link to pre-award)

OSP prior approval is required during the award management if the:

need for cost sharing is determined after an award is received.
cost share exceeds the amount committed in the proposal.

A no-cost extension (NCE) allows the PI additional time to complete the project’s scope of work without additional funding.

A Grantee Approved No Cost Extension relates to an extension that can be processed by an awardee under expanded authority for up to 12 months.

When applicable, the PI can request OSP approval and assistance with such an extension. The requests must include a programmatic justification and the requested period of extension. Additional information regarding use of unobligated balances during the extension period may be necessary based on sponsor requirements.

Pre-award costs are defined as those incurred prior to the effective date of the federal award or subaward start date and are necessary for efficient and timely performance of the scope of work.
A detailed justification is required to process requests for pre-award costs up to 90 days prior to the initial budget period of the award.

Process

The Principal Investigator (PI) contacts and works with the Research Support Team (RST) to initiate requests via myResearch.
The RST reviews the request and ensures that all corresponding information and supporting documentation are complete before submitting approval requests to the Office of Sponsored Projects (OSP).
OSP may:
- review and approve the request, and update the corresponding records in myResearch.
- request additional information from the RST submitter.
- decline the request and provide supporting information to clarify why the request was declined.

Resources

GW Processes (GW login required)
myResearch
GW Resource: Cost Sharing
GW Resource: Institutional Support
Uniform Guidance: Pre-Award Costs
Uniform Guidance: Expanded Authority 200.308 (g)

Frequently Asked Questions

What is the difference between an administrative establishment, an administrative establishment extension and an administrative funding request?

Administrative Establishment: An at-risk advance account set up at GW for awards that could be forthcoming, but are not currently funded.

Administrative Establishment Extension: Extension of an at-risk advance account at GW if an award is delayed and/or in negotiation and acceptance stage, but not fully executed.

Administrative Funding: Current award status is changed to at-risk to facilitate research continuity while the PI awaits the fully executed award modification.

What is expanded authority?

Authority granted to an institution by a sponsoring agency to manage certain cost related and administrative actions without prior written approval; namely, pre-award costs, one-time extensions, carryforward of unobligated balances to subsequent budget periods.

How do I know if my award is under expanded authority?

The fully executed agreements and the award standard and special terms and conditions should be referenced. The GW school research support teams and the Office of Sponsored Projects award management personnel can assist with clarifications.

When should I consider doing an internal rebudget?

You can perform an internal rebudget if:
1. you identify that the budget may not have the correct lines set up as initially proposed.
2. it is required to process a subaward.
You should not perform a rebudget to match the budget lines to the expenditures.

What are the timelines for OSP review and action?

Requests must be submitted 3-business days prior to the deadline for action.

How do I know if a request submitted to OSP has been approved?

myResearch Award Modification Request approval automatically generates an alert for the request submitter within the system. GW research community can find the status of pending actions within myResearch based on their access privileges.

Support

For research support team (RST) contact information, click here.
Office of Sponsored Project Teams
For assistance with myResearch, email myresearchgwu [dot] edu (myresearch[at]gwu[dot]edu).