Q – I’m expecting a subaward for my PI from another institution, but it’s really late! Is a Pre-Award Number (PAN) allowable for an incoming subaward?

A – Yes, in most cases. It has come to our attention that there is a widespread belief that OSP will not issue PANs for incoming subawards. We’re not sure how this “rumor” got around. But, it is not true! It is very true that OSP cannot issue PANs for clinical trial contracts. This applies mostly to those from corporate sponsors and would apply to any subcontracts under these types of awards. However, if your PI will be participating on an NIH grant with another university, or a similar type award with any other institution, a PAN would be allowable. In fact, in many cases it is advisable as some times subawards are late in getting to us. This is exactly the situation that could warrant a PAN! Some things to remember:

• As with any PANs, all costs are incurred at the department’s risk. Therefore, it is wise to have confirmation from the prime organization that they have received their award and intend to issue a subaward to Emory. It is also advisable to have a general sense of the amount they intend to award to be sure to keep provisional spending at an appropriate level.
• Because each school business office will need to approve your PAN, it is up to that office to determine what they believe is an appropriate level of documentation to support your PAN request.
• Again, as with any PAN, you must provide a department “guarantee” Smart Key which will be used in the event that the subaward is ultimately not forthcoming.

Remember, all PAN are “at risk” spending. Therefore, they should not be requested without care. However, in those cases where we have confidence that a subaward will be forthcoming and we will begin to spend, a PAN is the correct action.  It allows the charges to be charged in the correct location and avoids the need for cost transfers later (cost transfers that could be denied if in violation of the cost transfer policy).

If you have questions on the allowability of any PAN request, please feel free to seek guidance from the appropriate OSP analyst.