Office of Research and Project Administration
SPONSORED PROGRAMS COMPLIANCE
Documenting Expenditure Pre-approvals
Your particular
agreement may require pre-approvals by the sponsor for certain types
of expenditures. In these cases, the sponsor is saying that they want
to review these expenditures before allowing them. Without this approval,
they are therefore UNALLOWABLE costs.
Be on the lookout for approval requirements related to:
-
travel (particularly foreign)
-
other expenses specified for special approval
Prior approvals must be in writing from the Grant or Contract Officer. E-mail is one way to record this approval, particularly for grants. Contracts may require an actual signature. Note that all request for approval must be submitted or co-signed by ORPA.
Without documentation of this approval, expenditures for such costs will be unallowable, even if you have verbal authorization from the sponsor. It's not unusual for this type of expenditure to be reviewed in a postaward or closeout audit, which can occur years after the expenditure took place. Without the documentation in the file, it is likely that such costs will be disallowed, and will have to be paid with department funds.
While it is important to remain in communication with the technical officer when such conditions warrant, these kinds of pre-approvals must come from the sponsor's administrative officer.
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