There may be instances in which researchers find it necessary to incur costs prior to the effective date of an award. In such cases, there are two types of pre-award spending that can be requested.

• 90-Day Pre-Award Spending under Uniform Guidance: Federal grants and cooperative agreements issued under Uniform Guidance by sponsors participating in the Federal-Wide Research Terms and Conditions authorize Princeton to incur Pre-Award Costs 90 calendar days prior to the award effective date.  
• Internal Pre-Award Spending Authorization: For awards not issued under Uniform Guidance, Departments may, under certain circumstances, request the creation of a new award in PS  Financials to incur costs prior to the receipt or execution of a new award. In such cases, all pre-award costs incurred are at the risk of the Department, and must be backed up by a non-sponsored project funding source.

Already have a Prime Award Number?

• If you would like to request 90-Day Pre-Award Spending under a Uniform Guidance award, a completed and signed OPAR form should be submitted to ORPA with the required information in the 90-Day Pre-Award Spending section.
• ORPA will determine if the sponsor permits 90-Day Pre-Award spending, and if it is permitted, the requested Pre-Award date will be entered in PS Financials.

Do Not Have a Prime Award Number?

If you would like to request the creation of a new PS Financials Award prior to your award document being issued or fully executed, a completed and signed OPAR form should be submitted to ORPA with the required information in the Departmental Spending Authorization and Spending Prior to Award Activation sections.

Approval of the request is subject to the following conditions:

• The sponsor must allow for pre-award spending.
• A department chair or center/institute director signature and a departmental chart string are required on the OPAR form, in addition to that of the PI or designee.
• You must also provide a written indication from the sponsor that an award is forthcoming.
• In the event that the award is not issued or the pre-award costs are disallowed by the sponsor, any costs incurred will be transferred to the departmental chart string provided on the OPAR form.
• Please see the forms library to access the ORPA form.

ORPA is responsible for the negotiation and acceptance of sponsored awards and is the sole authorized entity to execute a sponsored project award on behalf of the University. When the sponsored award is fully executed, ORPA will establish an award in PS Financials and issue the PI, Department, and Sponsored Research Accounting (SRA) a Notice of Award (NOA), along with a copy of the award document.

It is the responsibility of all parties to become familiar with the details of the award and any relevant award restrictions and requirements. In addition, all parties must ensure regulatory compliance in key areas:

• Export controls
• Responsible conduct of research
• Financial conflict of interest in research
• Human subjects research
• Animal care research
• Biosafety hazards and biosafety

Federal contract awards typically include a Federal Acquisition Regulations clause (FAR 52.222-54), which requires the University to verify all personnel working on the federal contract award. This regulation states this initial verification must be completed within 90 calendar days after the effective date of the award. 

ORPA requires the completion of the E-Verify Notification and Approval form (found in our Forms Library) prior to fully executing a federal contract award. The reviews are performed by Human Resources, the Graduate School, or the Dean of the Faculty, as appropriate.

Once this initial review and approval is completed,  it becomes the Department/PI's responsibility to secure supplemental verification for any personnel added to the project who were not included in the initial screening. 

Research is collaborative environment.  There my be instances where these collaborators are at other institutions and must be engaged using a subaward agreement.  Details on Princeton's subaward process can be found on this website.

During the award and at completion, the University must fulfill the reporting requirements outlined in the terms and conditions. This reporting is a key component of sponsored research, and it offers an opportunity for the PI to report on the progress of the proposed research.

Depending upon the type of award (grant, cooperative agreement, contract, or other transactions), reports are due on a recurring basis during the life of the award, normally within 90 days of the final expiration date for all final documents. Ultimately, it is the PI’s responsibility to assure that all required technical reports have been provided in accordance with sponsor timelines, terms, and conditions. Failure to do so may result in delayed or cancelled funding, non-payment, or early termination.

Refer to your Notice of Award (NOA) and sponsored award document for complete reporting requirements, including report types, expected frequency, and recipients.

COMMON REPORTS

• Principal Investigator: Technical Reports, Project Outcomes (NSF), Public Access / PubMed (NIH)
• ORPA: Property(Equipment) Reports
• Sponsored Research Accounting (SRA): Financial Reports, Invoices
• Office of Technology Licensing: Intellectual Property / Invention Reports

Princeton follows cost principles required by Uniform Guidance. The cost must be (1) allowable, (2) allocable, (3) reasonable, and (4) consistent. 

Sponsored Research Accounting (SRA), part of the Office of Finance and Treasury, is responsible for all aspects of financial management related to sponsored research at Princeton. Throughout the Sponsored Research Lifecycle, they serve as a resource and guide to both you and your Department.

SRA RESPONSIBILITIES

SRA assists with all aspects of project financial management, from award initiation through close-out. This may include:

• Accurate reporting: SRA ensures that all reported financial data is accurate and timely.
• Timely payments: SRA facilitates prompt reimbursement by sponsors for all research costs.
• Award closeout: At the end of a project, SRA reviews expenditures to ensure that all charges are allowable, allocable, reasonable, and consistent, as per the approved project parameters.

Specific SRA tasks map to each individual project. Learn more about Sponsored Research Accounting, and find a list of departmental contacts.

At various points in a sponsored project lifecycle, a need may arise to seek approval from the sponsor to alter the original intention of the award. These changes can include, but are not limited to:

• Change in PI/co-PI
• Addition or deletion of subawardees
• Addition of program income
• Change in scope 
• Transfer of participant support costs

ORPA can assist in securing the sponsor approval. Please complete the OPAR form and provide the required documention mentioned on the form and ORPA will work with the sponsor to secure approval for the changes.

As projects evolve, plans can change. If such changes result in a budget that no longer matches the latest version received by your Sponsor, you may need to submit a rebudgeting request. Many sponsors allow flexibility in the reallocation of costs to adapt to needs of the project, so you should check the award document for guidance on sponsor requirements.

WHEN IS A REBUDGETING REQUEST NEEDED?

While individual sponsors vary in their policies on rebudgeting, a few general guidelines should be observed.

• Change in scope: On most federal awards, any rebudgeting that results in a change in the scope of the project requires sponsor prior approval.
• Budget deviations: Significant rebudgeting, such as when a single direct cost category deviates from the approved budget by 25% or more of the total obligated award amount, is a potential indicator of a change in scope, and could require Sponsor prior approval.
• Prior approval requirements: Some awards have prior approval requirements for individual direct cost items; such requirements will be indicated on the NOA.

If in doubt about whether sponsor approval is needed, you should consult with your ORPA administrator.

HOW DO I SUBMIT A REQUEST FOR REBUDGETING?

If you would like to submit a request for rebudgeting, you should submit an OPAR form with an explanation of the changes and why they are necessary, along with an OPAR Budget Distribution form, indicating the changes to the affected cost items.

If sponsor approval is required, ORPA will transmit the official request to the sponsor.

If the request is approved by the sponsor, the ORPA Award Specialist will revise the award budget accordingly and issue an updated NOA acknowledging the approval.

While many sponsors allow awardees to carry forward unspent funds from one budget period to the next, certain award types have restrictions on carryover and require prior approval before such unspent funds may be used. Your Notice of Award (NOA) will indicate if approval for carryover of funds between budget periods is required.  Please note that subawards are also impacted by carryover requirements.  Please contact your Subaward Administrator for assistance.

NOTE ON SPONSOR APPROVAL

In cases where sponsor approval is required, ORPA and Sponsored Research Accounting (SRA) will restrict the affected funds while approval is being sought, coordinate the request for approval with the department and the sponsor, and if approval is granted, authorize the continued use of the funds in PS Financials. 

If additional time is required to complete a sponsored project without the need for additional funds, the PI may request a no-cost extension. Expanded Authorities, which allow the University to authorize certain administrative changes to a sponsored award without prior sponsor approval, include no-cost extension requests.   

Request an Extension

To begin a no-cost extension request, complete and submit to ORPA the Prior Approval Request (OPAR) Form, found in the Forms library. Please include the original and anticipated new end date, along with the unexpended balance. The PI will be asked to certify that the extension is not being requested simply to expend unspent funds, and that the project scope will remain unchanged.

Prime Quick Guides are available for departmental use.

• Use the Award Quick Guide to learn about:
  • The new Prime award structure
  • How to find obligated/anticipated dates/dollars on sponsored research reports
  • What the different award/project/activity statuses are and what they mean
  • How to view award and subaward attachments
• The Requesting Access to Sponsored Research Reports Guide includes:
  • Definitions of the various Sponsored Research Reporting Access roles
  • Who has default access to Projects
  • How to fill out the Prime Financials Access Request form for sponsored research access.
• The Subaward Invoice Approval Quick Guide is:
  • A one-page guide on how to approve subaward invoices in Prime.
• The Viewing Award and Subaward Attachments Guide shows:
  • How to view award and subaward documents in Prime.
  • Troubleshooting instructions for when attachments don't want to open