Advance Accounts provide PIs and Departments with an opportunity to initiate a project and begin accruing charges for that project prior to receipt of an award document. The following procedure outlines the process to determine whether an Advance Account is appropriate, as well as what is required to make that determination. Note that Advance Accounts allow charging of expenses beginning on the project start date; Expenses prior to the project start date (“Pre‐Award Costs”) should not be allocated to an Advance Account. The procedures listed below are for Advance Accounts only, not Pre‐Award Costs. In addition, though Advance Accounts will allow most types of spending to commence, certain expense categories will be restricted. Outgoing Subcontracts to fund other institutions cannot be created using Advance Account funds.
An Advance Account can be requested by completing a University Prior Approval System Form (UPAS). After completion and execution by the PI and Department Staff, the UPAS is forwarded to OSP/BMRA for internal review. OSP will review the UPAS for completeness, and potentially request back‐up information if applicable. Advance Account requests that may require back‐up include, but are not limited to, the scenarios listed below:
- Incoming Subcontract Advance Account: OSP will request written confirmation from the Pass‐Through Entity that indicates a subaward is anticipated. This communication can take the form of an e‐mail or memo, and should include the anticipated start date of the subcontract.
- Federal Award (NIH, NSF, DoD, NASA, DOE, etc.) Advance Account: OSP will request that any substantiating information, such as an e‐mail from a Program Officer indicating an award is forthcoming, be included as part of the Advance Account Request.
As with the set‐up of all awards, prior to the creation of an Advance Account OSP will review internal documentation to ensure all pre‐award requirements are met. This can include:
Evidence of a complete, approved COEUS record (required for all Advance Accounts)
Documentation of IACUC/IRB approval, as appropriate
Completion of all required trainings, particularly Financial Conflict Of Interest (FCOI)
training required as required by the sponsor
Assurance from Office of Research Integrity that the award is cleared for set‐up from an FCOI standpoint
With Hierarchy Proposals, additional steps may be needed to assess the structure of potential Advance Accounts
OSP will also evaluate the circumstances of the Advance Account request. Based on the award type and potential award terms, it is possible that OSP may need to contact the Department for additional discussions regarding institutional/departmental risks associated with the Advance Account.
Possible Negotiation Issues and Risk:
In the majority of cases, OSP will establish an Advance Account upon request without any further discussion needed. There are some cases, however, where significant negotiation of areas of concerns to the PI, the department, and the University may be required. In these instances, prior to establishing the Advance Account, the Pre‐Award office representative will identify areas of concern and the associated financial and non‐financial risks, to the extent these risks can be identified, to ensure the PI and his/her department are aware of the potential obstacles that must be addressed before an award can be accepted on behalf of the University. Examples of negotiation issues include, but are not limited to, control of scope of work and key personnel; publication restrictions and confidentiality requirements; lack of criteria for acceptable performance; intellectual property terms; termination and default clauses; and indemnification. In addition, in some cases the very act of creating an Advance Account could create negotiation difficulties because some sponsors deem the award agreement accepted when work commences on a project. OSP will make the department aware of these potential impediments to award acceptance, and will create the Advance Account upon written confirmation that the Dean, Department Chair, or Center/ Institute Director is aware of these risks. In requesting and accepting an Advance Account on behalf of a PI, the department, school, or center assumes the total financial risk in the event the award is not made, not accepted, or if the terms of the award deem certain expenditures to be unallowable. OSP will use its best efforts to finalize an award, but cannot guarantee a successful outcome of any award negotiation. Note that in cases where agreement terms can have a substantial impact on the University as a whole, such as awards that may put Brown’s Fundamental Research Exemption at risk, Advance Accounts may not be possible.
Anticipated Timeline of Advance Accounts:
It is anticipated that Advance Accounts will be created for short‐term purposes, and therefore all Advance Accounts will be converted to Active awards within a reasonable timeframe. As such, accounts that remain in Advance Status an extended period of time will need to be reapproved by OSP after 6 months have elapsed. A rationale for extending the Advance Account will be requested as part of this evaluation, and OSP will then determine whether it is reasonable to extend the period of the Advance Account and communicate its decision to the department. If the extension is not approved, the Advance Account must be closed and all charges will be transferred to Departmental Accounts.
Closing an Account in Advance Status:
OSP is responsible for removing expenditures from the advance account if the award is not made, not accepted, or if the terms of the award deem expenditures to be unallowable. The expenditures will be written‐off against the cost center or other preferable worktags provided by the department.
Date version: September 18, 2017