Processing Pre-Award and Post-Award AtRisk Requests Job Aid
March 24, 2016
Purpose
Terminology
OAF Access
OAF Review
Risk Assessment
Final Processing
Risk-Rating Assessment Chart
Additional Guidance and Resources
ERA Pre-Award Processing
Purpose
One purpose of the ORSPA Action Form (OAF) is for departments to request/place an
account in at-risk status on a sponsored project or a charitable grant. At-Risk requests for
time and/or funding can be submitted prior to award acceptance or during the project
period while awaiting the next award amendment. Evaluating At-Risk requests determines
the financial risk involved in allowing a project to be setup or continue with no sponsor
agreement/authorization in place.
Terminology
There are two primary types of at-risk requests. They are:


Pre-Award At-Risk
o These are requests for an account to be setup before the notice of award has
been fully executed.
o There are two common flavors to this type of request:
 Standard: The start date requested of the at-risk account is the start
date anticipated on the notice of award.
 Incur Pre-Award Costs: The start date requested of the at-risk account
is up to 90 days before the start date anticipated on the notice of
award. Many federal sponsors allow us to incur costs up to 90 days in
advance of the start date.
Post-Award At-Risk
o These are requests for time and/or funding to be added to an existing project
account family before an amendment has been fully executed.
OAF Access

OAF is submitted to the Award Management Team (AMT) via [email protected]. An
activation task will be setup and assigned to a designated Proposal and Negotiation
Team (PNT) GCO for Pre-Award request or the Award Management Team (AMT) GCO for
Post-Award requests.

Reviewer will receive an email (from [email protected]) notifying them an at-risk
activation task is ready for their review.
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
At-Risk activation task can be accessed by either clicking the “edit this activation” option
on the email or by opening the “My Activations” tab in the Sharepoint Activation site.

A hyperlink to the location of the At-Risk OAF packet should be included in the notes
section of the activation task. Right-click on hyperlink and choose “Open in New Tab”
option. Left-click on new tab to view OAF packet.
OAF Review
Return to ERA Pre-Award Process: At-Risk Review
1. For Post-Award requests, identify account(s) from OAF and open account(s) in Coeus in
display mode. In the following checklist, Coeus will be used to verify sponsor, funding
mechanism, current and anticipated end date, obligated and anticipated funding, and
Principal Investigator (PI).
2. Review OAF Packet for completeness using checklist below:
For Pre-Award Request, proposal number is provided
Section B date fields completed (Anticipated Award Period, Period of
Performance for Advance).
 The At-Risk period of performance should be less than or equal to 90
calendar days. If the request exceeds 90 days the RA/PI will need to
provide additional justification in the OAF stating why the longer At-Risk
account period is required. An At-Risk exceeding 90 days represents an
exception and requires Assistant Director of ORSPA approval for a
deviation of 90-day policy.
 For post-award, this normally begins the day after the obligated spending
period of account ends. Although, at-risk funding could be requested
during an authorized spending period so advance period should reflect
the period in which the at-risk funding will be used.
 At-risk requests should not be issued for ASU issued subawards,
however, an exception may be granted by an Associate Director of
ORSPA if the justification justifies a significant project need and Unit
Guarantee is required.
 At-risk requests cannot be requested on accounts affiliated with Industry
or an ASU Consortium.
Section B – Appropriate cost guarantee option selected (OKED Unit).
Section D – Budget section completed for advance funding request (Required for
Pre-Award requests).
 Change to “Each At-Risk request cannot exceed 25% of the first year
budget (if sponsor intends to release total amount of award) or 25% of
the expected amount of funds (if award will be funded incrementally).”
Documentation should be included with the OAF to confirm this but
proposal or most current award notice can be used to verify this
information.
 Funds are budgeted in categories appropriate to expected award budget.
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Section E - Adequate justification provided. Justification should address the
following at a minimum:
Pre-Award
 Why it is essential the project activities start prior to award acceptance?
 Do the potential benefits of moving forward with At-Risk outweigh any
risks, in particular financial risk? If yes, please explain.
 Documentation from Sponsor stating award is forthcoming or in-house
being negotiated and the anticipated start date is known.
Post-Award
 Why the work for this project should continue prior to receipt of award
modification?
 Why this is a low financial risk?
Section F - PI signed (via signature or email). Images of signature are not
acceptable.
3. For complete OAF packets, move on to Risk Assessment.
4. For incomplete OAF packets:
o Notify contact listed on OAF and request missing information.
o Record situation in Notes section of activation field (MM/DD/YY Reviewer Initials:
Comments).
o Allow 3 business days for the contact to supply missing information.
5. For no-response to inquiry, GCOs complete the following actions:
o Notify OAF contact you are closing task due to no response.
o Save mail notification in Pending Activation folder, rename folder to “ABC1234 AtRisk mm-dd-yy” and move it to the Miscellaneous folder within Sharepoint
Activations folder. A Miscellaneous folder should be created if none exists.
o Update task by changing status to Cancelled, adding comment for denial to
Activation notes and updating URL to task folder titled “ABC1234 At-Risk mm-dd-yy”
then click save.
Risk Assessment
Return to ERA Pre-Award Processing: At-Risk Review
1. Determine probability of award or modification being activated within the at-risk period
requested.
1.1. See How to Research Pending Award for NSF and NIH.
1.2. Access sponsor website, sponsor email/paper letter notice of forthcoming award,
ORSPA Contracts SharePoint task, or sponsor point of contact. Look for information
sufficient to make a determination, e.g., stated/implied date ASU will receive award,
status of contract negotiation, steps required before award will be completed/fully
executed, outstanding reports.
2. Verify status of deliverables. On the OAF is a check box which allows the Unit to confirm
the project is current with deliverables. If the current deliverable box is checked, no
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need to verify the report submission as by checking the box the PI/Unit has certified
they are current on the submission of deliverables.
3. Based on assessment, assign risk rating in accordance with Risk-Rating Assessment
Chart and move onto Final Processing.
Final Processing
Return to ERA Pre-Award Processing: Final Processing
1. Update Notes section of Activation task with findings and risk rating.
Use format: MM/DD/YY <Reviewer Initials> Review Notes: <Comments>
Example 1: 08/10/11 TS Review Notes: OAF packet complete; Unit guarantee account
has available funds to cover request; modification expected within the next 10 days; PI
current with deliverables; applying 1 risk rating.
Example 2: 08/10/11 KP Review Notes: ORSPA has received award T&Cs, Agreement
negotiated, awaiting sponsor signature, FDP Agency. Applying 1 risk rating.
2. Based on Risk Rating, complete processing of request as described below.
Risk Rating Level 1
 Request can be immediately processed for activation.
 Add the following comment to Notes section of Activation task (right above your
review notes):
“Under 1 risk rating and under <Unit or OKED> guarantee, I approve the at-risk
request for <time or time and funds> on <PROPOSAL or ACCOUNT>. <Full Name>
<Date of Approval>.”
Risk Rating Level 2
 Notify OAF contact via email of risk rating. Email should state the Department must
take action within 2 business days to stop processing otherwise request will be
processed for activation.
 Request can be processed for activation.
 Add the following comment to Notes section of Activation task (right above your
review notes):
“Under 2 risk rating and under <Unit or OKED> guarantee, I approve the at-risk
request for <time or time and funds> on <PROPOSAL or ACCOUNT>. <Full Name>
<Date of Approval>.”
o If sponsor is a Department of Defense Agency and award will be via contract, add
comment:
“Under 2 risk rating, <Unit or OKED> guarantee, and written record of DOD
Contracting Officer (a) determination of ‘fundamental research’ and (b) approval
of pre-award costs, I approve the at-risk request for <time or time and funds>
on <PROPOSAL or ACCOUNT>. <Full Name> <Date of Approval>.”
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Risk Rating Level 3
 Notify Department Chair/Director and copy OAF contact via email of risk rating.
Email should state the Department Chair/Director must take action within 2 business
days to indicate acknowledgement of risk and decision to move forward despite risk.
Activation will continue upon receipt of decision. If no response after 2 business
days, activation process should be terminated following task cancellation instructions
in Step 5 of OAF Review section.
 Request can be processed for activation once all approvals received.
 Add the following comment to Notes section of Activation task (right above your
review notes):
“Under 3 risk rating and under Unit guarantee, the Unit has approved the at-risk
request for <time or time and funds> on <PROPOSAL or ACCOUNT>. <Full Name>
<Date of Approval>.”
o If sponsor is a Department of Defense Agency and award will be via contract, add
comment:
“Under 3 risk rating, Unit guarantee, and written record of DOD Contracting
Officer (a) determination of ‘fundamental research’ and (b) approval of pre-award
costs, the Unit has approved the at-risk request for <time or time and funds> on
<PROPOSAL or ACCOUNT>. <Full Name> <Date of Approval>.”
3. Update Activation task and save changes.
 Assigned To field - change to AMT GCO assigned to unit. This will most likely be the
same person listed in the ORSPA Contact field.
 “Rush” checkbox is checked.
 Status field - change to “Awaiting Verification”.
 Secondary Status field – change to “In Progress”.
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Risk-Rating Assessment Chart
Return to ERA Pre-Award Processing: Risk Assessment
Risk
Rating
Pre – Award At-Risk Request


Award with no critical or onerous
terms* and conditions in proposed
award document
Start date contained in proposed
award document or some other firm
commitment to start date.
 Award with no critical or onerous
terms and conditions in award
document.
 PI is current with the submission of
project deliverables (i.e. progress
reports).
 Documentation from sponsor
indicates that award modification is
forthcoming.
 Award mechanism is a grant.
 Sponsor is federal, subfederal or a
common sponsor which we’ve had
no current payment/collection
issues with.
Previous history of protracted or
contentious negotiations with the
sponsor (disproportionate to the
complexity of the agreement and the
scope of the project).
Presence of one onerous term or
condition in proposed award
document.
No previous negotiation history with
the sponsor.
Non-standard payment* terms
Agreement is fully-executed awaiting
sponsor pre-payment/reserve.
Informal/email notice that grant
transfer is in process and anticipated
period of performance and
anticipated funding increment are
specified.
DOD award is expected via contract
and ASU received Federal Agency
Contracting Officer
o Determination that the ASU
research project is fundamental
and confirmation that pre-award
expenditures are allowable.**
 All 2nd At-Risk requests.
 PI is current with the submission of
project deliverables (i.e. progress
reports).
 Packet doesn’t contain any
correspondence from sponsor
regarding status of award
modification.
 Sponsor is mid-level risk meaning
we may have had previous (over 1
year) problems with
payment/collection or negotiations
but not currently.
No official indication of firm start
date for award.
 All 3rd or greater At-Risk requests.
1




2


3

Post – Award At-Risk Request
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






Historical sponsor preference for
making the effective date of award
the date when the contract is fully
executed.
Presence of multiple onerous terms
and conditions in proposed award
document.
Presence of one critical term or
condition in proposed award
document.
Sponsor refusal to make prepayment
or issue an Authorization to Proceed.
History of payment problems with
sponsor.
Sponsor has not formally responded
with draft agreement
DOD award is expected via contract
and ASU has not received Federal
Agency Contracting Officer
o determination that the ASU
research project is fundamental
and confirmation that pre-award
expenditures are allowable.**
March 24, 2016
 PI is not current with the
submission of project deliverables
(i.e. progress reports).
 Packet doesn’t contain any
correspondence from sponsor
regarding status of award
modification.
 Sponsor is a high-level risk
meaning we are currently having
problems with payment/collection
or negotiations.
 OKED will NOT guarantee level 3 at-risk accounts regardless of sponsor or
faculty status (EARS).
 Unit Chair/Director must provide written approval to move forward with level 3
requests.
* See Definitions
** Department of Defense (DOD) contracts include DFAR 252.204-7000 Disclosure of
Information (Aug2013). This provision requires DOD Contracting Officers (CO) to determine
if research projects are considered fundamental as defined by National Security Decision
Directive 189. ASU has been advised not to begin project activities until receipt of CO
written determination.
Additional Guidance and Resources
Return to OAF Packet Review Checklist (OAF Review #2).
Qualifications for OKED Guarantee
PI is an EARS faculty member listed on the current EARS Faculty list.
OR
Funding mechanism is a Grant or Cooperative Agreement
AND
Sponsor is one of the following:
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AFOSR - Air Force Office of Scientific Research
EPA - Environmental Protection Agency
AMRMC - Army Medical Research and Material
Command
HUD – Housing and Urban Development
ARO - Army Research Office
NASA - National Aeronautics & Space
Administration
DOJ – Department of Justice***
DHS – Department of Homeland Security
NIH - National Institutes of Health
DHHS – Department of Health & Human
Services
NOAA – National Oceanic & Atmospheric
Administration
DOC - Department of Commerce***
NSF - National Science Foundation
DOE - Department of Energy***
ONR - Office of Naval Research
DoED – US Department of Education
STScI – Space Telescope Science Institute
DOI – Department of Interior
USDA - US Department of Agriculture
DOS – Department of State
For Post-Award Time Only At-Risk Requests:
Awards where obligated amount was paid in full and the account has an available balance.
For Pre-Award At-Risk Requests to Incur Costs Before Anticipated Start Date
*Note special limitations per Sponsor/Program:
–
US DOJ does not automatically allow Applicants selected for award the ‘expanded
authority’ to incur pre-award costs during 90 days before award start date. DOJ award
documents stipulate several Special Conditions that must be met before Grantee is
allowed to obligate costs, expend, and/or drawdown funds. ASU must obtain DOJ
approval for expenditures during 90 days before start date and before certain Special
Conditions are met (even after award effective date).
–
US DOE typically authorizes Applicants selected for award to incur up to $20k in preaward costs at-risk during award negotiation. DOE requires Selectees to obtain prior
approval to incur costs exceeding threshold.
–
US DOC rarely allows pre-award spending.
In all cases review funding announcement and Sponsor policies regarding allowability of
pre-award expenditures.
Additional Requirements for At-Risk Requests backed by Unit Guarantee
Unit Guarantee account:

Is non-sponsored and active,

Section B – authorized account signer approval provided. Signer must be listed as a
signer on the Advantage ORG1 screen. Approval can be done via email and should be
included with OAF packet, and

Has available funds, equal or greater than the advance amount requested (if any).
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Example 1: The anticipated award is $100,000. The unit may request up to $25,000
for the at-risk pre-award account. The unit guarantee account must have at least
$25,000 funds available.

For requests to extend time-only, the guarantee account must have an available balance
equal or greater than 25% of the funds available in the at-risk account.
Example 2: Unit requested at-risk for time only and the available balance on the
existing account is $100,000. The guarantee account must have at least $25,000
available ($100,000 x 25% = $25,000).
HOW TO RESEARCH PENDING AWARDS
Note re: Grants
Re: NSF. Ideally OAF supporting documentation includes a copy of FastLane confirmation of
forthcoming award. If it does not, GCO can find status in FastLane (or ask RA to locate and
add information to OAF package):
(1) Access FastLane “Organizational Reports” module, click Report Type “Recent
Proposals”, click Status “Recommended for funding”, enter PI’s Last Name, find
appropriate proposal, and open the Proposal Information page.
(2) The Information page specifies the anticipated award start date and duration, as
well as date the Division of Grants and Agreements received the recommendation for
award; it also includes standard caveats that award issuance may require four weeks
or more and an award is not guaranteed.
(3) Print the Information page to pdf and add to the ERA activity for OAF.
Ideally the OAF supporting documentation also includes a copy of the final budget or ERA
includes a clearly marked copy. If not, GCO can find acceptable documentation in FastLane
(or ask RA to locate it and add to OAF and ERA):
(1) Access FastLane “Forwarded/Submitted Revised Budgets” module, “Submitted by
SPO” page, and “Proposal ID” (NSF proposal number assigned after submission).
(2) Open the final approved budget (highest numbered “Submitted Revision”).
(3) Print Year 1 of the final approved budget to pdf (or snip it) and add to the ERA
activity for OAF.
Re: NIH. Ideally OAF supporting documentation includes copy of (a) an email from Program
Official or the Grant Management Specialist or (b) the eRA Commons Status Information
page indicating NIH intent to award the proposal. If none of these are included, GCO can
find documentation in Commons (or ask RA to locate and add information to OAF package):
(1) Access eRA Commons “Status” module, click “General Search” option, search by
PI name, find appropriate proposal, and click “Application ID” to open the “Status
Information” page.
(2) See “Status History” block and “Status Message” on top row.
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- If status is “Council review completed” or “Pending administrative review,” GCO
can email or call Grants Management Specialist (GMS) for information, e.g.,
decision to award, anticipated award effective date and start date.
- Print the Status Information page to PDF and add GMS information (email
message or phone comments) to GCO’s Review notes.
Note re: Contracts
 GCO processing At-Risk request may consult GCO Principals for assistance.
 GCO confirms pre-award expenditures are allowable.


GCO contacts Contracting GCO for status of negotiation.
o If agreement is negotiated and GCO anticipates it will be fully executed within a few
days, it is appropriate to inform RA of status and cancel OAF processing. However,
some factors may indicate it is prudent to complete OAF processing and establish
pre-award account.
o If agreement includes onerous or critical terms*, non-standard payment terms*, or
other problematic terms, negotiation may be prolonged or agreement may not be
reached. Such terms influence determination of risk associated with establishing a
pre-award account. Contracting GCO.
Record pre-award action in Contracts SP task, e.g., “(Date Initials) Pre-award account
established beginning [date]. Action needed: Please ensure agreement effective date
occurs on or before pre-award start date.”
* If award T&Cs include export control language, follow standard process re: notification to
[email protected].
*DEFINITIONS
Onerous terms and conditions: Term or condition forfeits rights of the State of
Arizona, impacts revenue, or results in significant extra work for the PI and
University. Onerous terms can often be negotiated or ameliorated. Examples
include: indemnification, choice of law or venue, invoicing by labor hour, payment
holdback, and excessive reporting requirements.
Critical terms and conditions: Term or condition that forfeits rights of the State of
Arizona and/or contravenes key academic principles. Critical terms are difficult to
negotiate or ameliorate and there is a moderate to high probability of impasse.
Examples include: dissemination of information, work for hire, and ownership of
intellectual property.
Non-standard payment terms: Payment terms that are not consistent with
generally accepted cost-reimbursement processes or fixed-price milestone payments.
Examples include: payments made to ASU contingent on sponsor receipt of funds
from the prime sponsor, payment holdback provisions, and requirements to itemize
costs on a fixed-price agreement.
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ERA Pre-Award Processing
This work instruction contains the following sections:
Purpose
Funding Anticipated
At-Risk Review and Assessment
Review
Risk Assessment
Final Processing
Essential Data Elements Required for New and Transfer Awards
Purpose
Requests for pre-award account set up are initiated, reviewed, and approved in ERA.
Funding Anticipated
1. Pre-Award GCO who submitted proposal receives RA’s ’Notify PNT’ message with
attached OAF packet in ERA “My Inbox” that PI is requesting a pre-award account for
forthcoming award.
1.1. At-Risk requests are managed by the GCO who submitted application unless GCO
requests reassignment to ensure timely processing.
2. GCO runs ERA activity
.
2.1. After running ERA activity the proposal application state changes from
to
3. GCO runs ERA activity
3.1. ERA state automatically changes to
.
.
.
4. If relevant ERA activities are not available options to proceed depend upon current ERA
state:
4.1. When ERA state is ‘Agreement Under Review’, click ‘Cancel PNT Agreement Review.’
Process at-risk request per standard practice. Upon completion, return ERA state to
‘Agreement Under Review’. After completing At-Risk processing, run ‘Award Letter
Received’ to update ERA state for Contracting Officer.
4.2. When ERA is in other states utilize the ‘Public Comment’ activity. After performing
evaluation and recording review notes and disposition in the Public Comment,
inform AMT of approved at-risk request via email to [email protected].
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At-Risk Review and Assessment
Review
1. GCO opens ERA activity
.
2. GCO assesses OAF Packet for completeness using OAF Review Checklist above (OAF
Review Item 2).
3. If OAF packet is complete, proceed to Risk Assessment.
4. If OAF packet is incomplete or if questions arise:
4.1. GCO clicks disposition ‘Request RA At-Risk Changes’ and notes missing information
or questions.
4.2. ERA automatically changes proposal application state from
to
.
4.3. GCO receives RA response via ’My Inbox’ or views RA response on ERA History
tab/workspace, reviews, and if OAF packet is complete, proceeds to Risk
Assessment.
Risk Assessment
1. GCO determines risk level using Risk-Rating Assessment Chart above.
2. Obtain PNT Associate Director (or designee) approval to proceed if
2.1 OAF request is to support a project that will be awarded via contract and/or
2.2 risk rating is 3 (even if Unit Guarantee Account is provided).
2.3 An email template is available in the Proposals folder at the PNT Home SharePoint
site, Reference Documents link.
Final Processing
1. After request is approved by GCO (Associate Director, if applicable), GCO updates the
ERA activity
and enters review notes and activation approval
instructions in accordance with Final Processing above.
2. After GCO clicks OK, ERA-automatically
2.1. changes proposal state to
and
2.2. generates activation request in AMT Task List.
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Essential Data Elements Table
New Federal Sponsor Award
to ASU
Notice of award status via
Sponsor’s web portal
Email from Program Official
stating proposal has been
recommended for funding and
is awaiting upper level
approval
GCO calls Sponsor Grant
Manager/Grant Management
Specialist for confirmation that
award is in process
New Pass-Through Award
(PTE,
Sub-Federal funds) to ASU
Transfer Pass-Through
Award (Sub-Federal funds) to
ASU
PTE Sponsored Research Office
email confirms sub-award is in
process
GCO calls PTE central office,
obtains status of sub-award,
documents essence of
conversation, and sends to PTE
POC
Federal Sponsor notice via
website that transfer is in
process
Email from original grantee’s
sponsored research office
stating required steps to
relinquish award are complete
ASU received Sponsor’s draft
award agreement
Email from Prime Sponsor
Program or Administrative
Official confirming transfer
status
Sponsor’s formal letter (sent
via email or paper) that
proposal has been approved
for award and ASU will be
contacted to begin
negotiations
Draft agreement for specific
project that includes essential
data elements
Email from Program Official
stating status of forthcoming
award
Master agreement that
references specific project and
includes essential data
elements
ASU received Sponsor’s draft
award agreement
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