Summary:

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.

Procedure:

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