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COVID-19: Information from SPA/OSP/CGA

Request Hardship/Advance Account

There may be instances in which a department/faculty member wishes/needs to begin work on a project prior to completion/execution of an award document. Using an account unrelated to a specific project can be problematic.  The practice can be particularly problematic for federal projects.  Federal auditors may view that practice as a serious breach of internal control procedures that may damage the reputation of the faculty member, the department, and MSU. Due to the federal audit technique of sampling and extrapolation, a few inappropriate expenditures can be extrapolated to the entire population of MSU grants and contracts. This has the potential to multiply a small error into a large amount of questioned costs and potential disallowances. To minimize these occurrences, MSU makes available to departments two types of accounts: Advance Accounts and Hardship Accounts. Advance and Hardship Accounts allow the department to charge project expenditures to the correct account as project expenditures are incurred.

Advance Accounts are used when a PI has requested an expedited account setup. This setup can occur if OSP/BC has received a contract* or grant award to negotiate for the project and OSP/BC believes it can be successfully negotiated and accepted, all compliance approvals are on file (IRB/animal approvals, COI, export control, Institutional Proposal, etc...), AND the college has agreed to allow Advance Accounts. Please note that project reports should not be sent to the Sponsor until an award has been fully executed.

  • Over 99% of current contracts are successfully negotiated.
  • Advance Accounts will "normalize" the process, such that, the PI can begin work without additional paperwork.
  • CGA will assign a project account number after OSP approves the set-up of the account. No funds will be added to university ledgers until the award negotiation is completed and the agreement is fully executed.
  • In return for this expedited service, you are agreeing in advance, without specifically signing on to each proposal, to cover any expenses that might become non-reimbursable.
  • Advance Accounts can be immediately canceled.

*Special note for federal and for-profit contracts:

  • Federal contracts - in most cases the start date of the federal project is the date of signature on the contract. Expenses prior to the date of signature would not be allowable and would need to be removed from the account, unless approval is granted for pre-contract costs.
  • For-profit contracts - in many cases the start date of the for-profit funded project is the date of last signature on the contract. Absent specific allowances in the negotiated contract terms expenses may have to be removed from the account.

 

Colleges & Units below participate in Advance Accounts
Name Date Effective
College of Agriculture & Natural Resources 10-2-96
College of Arts & Letters 6-4-96
College of Communication Arts & Sciences 3-12-03
College of Education 1-10-97
College of Engineering 5-20-96
College of Human Medicine 6-14-96
College of Music 11-23-20
College of Natural Science 5-24-02
College of Nursing 5-30-96
College of Osteopathic Medicine 7-21-14
College of Social Science 2-18-13
College of Veterinary Medicine 5-15-96
James Madison College 9-15-16
MI Agricultural Experiment Station 10-14-98
MSU Extension 9-13-16
Facility for Rare Isotope Beams (FRIB) 12-1-97
Office of Research and Innovation (OR&I) 1-17-14
Urban Affairs Programs 5-10-96
University Outreach 9-28-04

 

Hardship Accounts are for those cases where the department wants an account number to be assigned, and expenses to occur on the correct project account, even though OSP/BC does not have a draft of the agreement. Hardship Accounts are different from "Advance Accounts" because with Advance Accounts, OSP/BC has already received the award. For OSP/BC to evaluate a Hardship Account request, please provide adequate information to indicate that an award is likely and what type of award will be issued, e.g., a grant award, for-profit contract, or a federally-funded contract (if the funding document is anticipated to be a Federally-funded contract, a Hardship Account generally cannot be issued since it is unlikely that pre-contract costs will be allowed). Please note that project reports should not be sent to the Sponsor until an award has been fully executed.

Hardship Accounts may be established via a memo from the unit administrator to OSP/BC (addressed to Contract Team 1 or 2 based on your college, or BC representative) requesting a Hardship Account and indicating that if the award is not made, expenditures made to that account will be covered from their departmental funds.  If it is anticipated that the project will be conducted in the University Research Organization (URO), please note that expenses disallowed by the sponsor are the responsibility of the Dept/College and not the URO.

The department may also request that the Hardship Account only be used for certain items (salaries, for example), or up to a certain dollar amount, i.e., not to exceed $50k.  Generally, Hardship Accounts up to $100k can be guaranteed by the department chairperson. If the department wants to expend in excess of $100,000 on the Hardship Account, an approval from the appropriate dean is required. Of course, Hardship Accounts cannot be setup until a Proposal Development document has been processed, and all compliance documents (IRB/animal approvals, COI, export control, etc.) are received by OSP/BC.

Hardship Extensions are used when an existing account has expired but additional money is expected.  This keeps the account open for payroll and Purchasing items.  Hardship extension requests need approval from the Department Chair which can be emailed to awards@cga.msu.edu. Alternatively, a department administrator can route an extension to an account in KFS via an account edit edoc, attaching the Chair’s approval or ad-hocking the Chair on the KFS route for his or her approval.

The Advance and Hardship Account types assume that:

 

Departments that are not included on the approval list for Advance Accounts, but would like to be, need to have the Dean/Director/Chairperson complete the Advance Account Sign Up form. The signed form can then be returned to CGA.

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