Sponsored Research: The Importance of Obtaining Approvals Before Starting Work

Authors: Holly Sommers, Associate VP, Office of Sponsored Programs & Edwin Bemmel, Associate VP, Research Grants & Contracts

All sponsored research is subject to specific regulations and requirements and must be administered through the designated offices. The Office of Sponsored Programs (OSP) verifies these requirements before approving an award or assigning a Provisional Award Number (PAN).  

Sponsored research activities can only be conducted after approvals have been provided by OSP and the related award and project(s) numbers have been issued. Institutional approvals are provided when: 

  • A Notice of Award or executed agreement has been received, and an award and related project(s) have been created and provided to the PI/department. 
  • A PAN request was submitted and approved & related project(s) were created and provided to the PI/department. 

Conducting research without approvals poses several risks, including: 

  • Lack of oversight and potential non-compliance with regulations.  
  • Difficulty demonstrating that compliance requirements were in place and met, resulting in an increased risk of audit findings. 
  • No or limited visibility and monitoring of project-related expenses. 
  • Inability to certify effort for personnel working on the project if salary posts on a non-sponsored speedtype or a project that is not for the correct budget period. 
  • Delays in submitting financial reports and potential unreimbursed costs. When expenditures remain on an expired budget period, the related project cannot be reconciled and final invoices or financial reports for that period cannot be created or submitted timely, resulting in an increased risk of invoices being denied, resulting in unreimbursed expenditures. 
  • Audit risks due to intentionally incurring expenditures on an incorrect sponsored speedtype. 

To ensure proper compliance and avoid these risks, researchers must: 

  • Obtain an official award and speed type before starting any research activities or incurring costs. This applies even when anticipating a future award or funding for subsequent budget periods. 
  • Never conduct research without the necessary approvals, as any associated expenditures might be deemed unallowable. 

 Before conducting any research activity and incurring associated costs, PI should always ensure that they have an award and speedtype issued based on a notice of award/executed agreement or an approved PAN. This includes subsequent budget period funding for awards without automatic carryover (new speedtypes are created for each budget period). Work should not be conducted unless either has been provided. Any expenditures incurred could otherwise be considered unallowable. 

By following these guidelines, researchers can ensure their sponsored research projects are conducted smoothly, compliantly, and efficiently. 

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