This information applies to:
All grants and cooperative agreements.
Recoverable costs which meet certain criteria set forth in the applicable Federal cost principles, that are incurred by the Applicant prior to the effective date of a grant- or cooperative agreement-funded project .
2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
Applies to all Financial Assistance Recipients
§200.458 Pre-award costs.
Pre-award costs are those incurred prior to the effective date of the Federal award directly pursuant to the negotiation and in anticipation of the Federal award where such costs are necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency.
USFWS FAPO 'Issuing a New Award Guidance' Step 4 A.3. (Dated March 14, 2014)
Applies to Service Personnel in the administration of financial assistance awards
Pre-award costs are any award-associated costs incurred prior to the award project period start date. See the Setting Project Period Dates for Grant and Cooperative Agreement Awards (Attachment 7) guidance document for more information on setting appropriate project period dates on an award including approved pre-award costs.
Programs not otherwise restricted or prohibited from funding pre-award costs must inform applicants in the NOFA that until pre-award costs are authorized under an approved award, the applicant has no assurance that the Service will reimburse these costs. The Notice of Funding Availability Template includes standardized text for this required notice. To qualify for pre-award cost reimbursement, an applicant must demonstrate in the application that some pre-award activities were necessary and reasonable for accomplishing the overall program objectives and would have been approved had they occurred within the project period.
Frequently Asked Questions
What should the project period start date be if we are authorizing pre-award costs?
The start date should not be backdated to incorporate pre-award costs. Pre-award costs, by definition, are incurred as a result of activities performed BEFORE the start of the project period. Pre-award costs must be specifically authorized in the notice of award.
Must a Federal awarding agency accept pre-award costs?
No. While the Uniform Guidance allows Federal agencies the option to waive prior approval of pre-award costs incurred less than 90 calendar days before the Award approval, the Agency is under no obligation to accept pre-award costs, even if those costs are allowable under normal circumstances (i.e. incurred during the award period). Incurring pre-award costs is at the Recipient's own risk. It is Service policy to require prior approval of ALL pre-award costs.
 2 CFR 200.308 (d)(1).