After the Award is Made…THEN WHAT?
Rebecca D. Claycamp, MS, CRAChief Grants Management OfficerNational Institute of Mental Health, NIH
Terri JarosikSupervisory Grants Management SpecialistNational Institute of Mental Health, NIH
JUNE 2012
When Does a Grantee Need to Contact NIH After the Initial Award?
When there is an issue with the Notice of Award (NOA)
Annual continuation progress reports, including multiyear funded grants
When an FCOI is identified Required prior approvals Consultation when a question needs to be
answered or a problem arises Closeout
Notice of Award (NoA)
What is the Notice of Award letter? What are the components of the NoA letter? Grantee acceptance of award
What is the Notice of Award letter?
Legally Binding Document Identifies grant number, grantee, PI Establishes funding level, support period Sets forth terms and conditions Includes NIH Contact Information for assigned
Program Director & Grants Management Specialist
E-mailed to the grantee-provided address Available in Commons Status
NoA Section I: Award Data & Fiscal Information
Summary totals for current and future years Fiscal year of award Indicates whether an unobligated balance has been
applied to the award amount Cofunding by another NIH Institute/Center or Office
NoA Section II: http://grants.nih.gov/grants/policy/awardconditions.htm,
info about: Grant Payment Information OIG Hotline Information Other terms/info that apply to all awards
Components of the NoA
Components of the NoA (continued)
NoA Section III: Terms & Conditions
Standard terms, by reference:
Grant program legislation and regulations
Restrictions on the expenditure of funds in appropriation acts
45 CFR 74 or 92 as applicable
NIH Grants Policy Statement
Components of the NoA (continued)
NoA Section III: Terms & Conditions
Dependent on award characteristics….
Federal Demonstration Partnership institutions noted
Carryover - automatic or prior approval
Included/excluded from Streamlined Noncompeting Award Process (SNAP)
Phase III Clinical Trials (when applicable)
ClinicalTrials.gov
Components of the NoA (continued)
NoA Section III: Terms & Conditions
Requirements for DUNS # and CCR registration
Transparency Act
Multi-Year Funded
Public Access
Closeout term (when applicable) Co-funding (when applicable)
Program Income
Components of the NoA (continued)
NoA Section IV: IC Special Terms and Conditions
Cooperative Agreement
Restrictive terms
Information items
Staff Contact Information
Spreadsheet Summary
Grantee Acceptance
The grantee indicates acceptance of the terms and conditions of the award by drawing down funds from the Payment Management System
FCOI Reporting RequirementsInitial and annual FCOI Reports are provided
to the NIH through the eRA Commons FCOI Module
Prior to the expenditure of funds During the period of award
Within 60 days of identifying a new FCOI Annually
At the same time as when the annual progress report or multiyear progress report is doe or at time of extension
http://grants.nih.gov/grants/policy/coi/index.htm
Progress Reports
SNAP or Non-SNAP Elements of a Progress Report How to submit When to submit
SNAP Progress Reports - Administrative & Fiscal RequirementsGrants Policy Statement, 8.4.1.2 Streamlined
Non-Competing Award Process
http://grants.nih.gov/grants/policy/nihgps_2012/nihgps_ch8.htm#_Toc271264971
Detailed budgets not required Federal Financial Report due at end of
competing segment eSNAP retiring, RPPR required
Research Performance Progress Report - Update
Guide Notice for RPPR changes (Feb. 2013) Progress reports for SNAP grants and Fellowships with
budget start dates on or after 7/1/13 must be submitted using the RPPR. eSNAPs will be “returned”.
Progress Report Additional Materials (PRAM) functionality expanded to include requests from ICs
RPPR for non-SNAP and multi-year funded awards implementation timeline TBD
More at: NOT-OD-13-035 and NOT-OD-13-061
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RPPR – Resources
NIH RPPR webpage• Background• NIH RPPR Instruction Guide• Archive of Webinar for NIH Grantees• Frequently Asked Questions
More at: http://grants.nih.gov/grants/rppr/index.htm
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Key Elements of the RPPR Progress Report
A. Cover Page B. Accomplishments C. Products D. Participants E. Impact F. Changes G. Special Reporting Requirements H. Budget
Are there still the three questions?
D.2a - Will there be, in the next budget period, either (1) a reduction of 25% or more in the level of effort from what was approved by the agency for the PD/PI(s) or other senior/key personnel designated on the Notice of Grant Award, or (2) a reduction in the level of effort below the minimum amount required by the Notice of Award?
Describe and justify the planned reductions
D.2b - Has there been change in the active other support of senior/key personnel since the last reporting period?
Provide complete other support only if active support has changed for the PI and key personnel, or new senior/key personnel are added
G.10 - Is it anticipated that an estimated unobligated balance (including prior year carryover) will be greater than 25% of the current year’s total budget?
Explain why there is a balance, (including prior year carryovers), > 25% of the current year’s total budget and how you plan to use the funds
Submitting a SNAP Progress Report Electronically via eRA Commons, 45 days
before next budget start date Commons-registered institutions and PIs:
Due date information accessible through the Commons Status system (electronic submission for SNAP)
Have access to pre-populated face pages via Status
eRA Commons Website: https://commons.era.nih.gov/commons/index.jsp
Non-SNAP Progress Report Requirements
Submit complete PHS2590 application Detailed budget, justification, and updated
other support, IRB and IACUC if appropriate
Address unobligated balance > 25%
Total Costs as commitment base Annual Federal Financial Report
(separate electronic submission) RPPR implementation timeline TBD
Key Elements of Non-SNAP Progress Report
Face Page Correct contact information Human Subjects/Animals
FWAs/Assurances IRB/IACUC dates Education Certification for new key personnel
Budget Page At committed level with written justification
Updated Other Support Progress Report Summary Checklist All Personnel Report
How to submit a Non-SNAP Progress Report
Hard copy to centralized mailing address, two months before next budget start date:
Division of Extramural Activities Support, OER, NIH
6705 Rockledge Drive, Room 2207, MSC 7987
Bethesda, M.D. 20892-7987
Bethesda, M.D. 20817 (courier/express)
Telephone: (301) 594-6584
What Not to Submit with the Non-Competing Progress Reports
Carryover requests Requests for supplemental funding Requests for additional time to the final
budget and project period
These are administrative actions that need to be addressed separately.
What Can Delay the Award Process?
Missing information for Key Personnel Out-of-date IRB/IACUC approvals Lack of population data for clinical trials Budgets with inadequate justification Other Support for an individual that
exceeds 12 CM (100%)
Timeliness All grantees have access to a searchable list
of due progress reports at:http://era.nih.gov/commons/quick_queries/index.cfm#progress
Two separate progress report reminders e-mailed to the PITwo months prior to the due date
Two weeks after the due date for overdue reports
Federal Financial Report Beginning 2/1/2011 NIH implemented the expenditure
data portion (i.e., FSR info) of the FFR Annual FFR due 90 days after the end of calendar
quarter in which the budget period ends Final FFRs due 90 days after the project period end FSR info under expenditure data of FFR.
Only cumulative data reported on FFR In the eRA Commons
(Federal Cash Transaction Reporting completed in Payment Management System on the FFR using cash transaction data elements)
Federal Financial Report (continued)
FFR SHOULD BE SUBMITTED BEFORE CARRYOVER REQUESTS ARE CONSIDERED
Grant might not be processed if a prior year FFR has not been submitted to and accepted by NIH
Expenditure data and cash transaction data on the final FFR must reconcile
Grants Policy Statement, 8.4.1.5 Financial Reportshttp://grants.nih.gov/grants/policy/nihgps_2012/nihgps_ch8.htm#_Toc271264973
Carryover/Offset – What’s the Difference? Carryover increases the approved budget
authorization using prior year funds A carryover is a “$0” transaction on the
NoA but the current approved budget is increased
An offset “partially pays” the current year’s grant with funds from a prior year – no increased budget authorization
An offset decreases the amount of the award
Requesting a Carryover… You must have an UNOBLIGATED BALANCE
reported on a FFR
Funds awarded in one year but not spent Carried forward from one budget period to another Requires a written request from the grantee including a
detailed budget page and budget justification Justification requires a rationale for why funds were not
spent in the year in which they were awarded and how they will be spent in the next year.
Justification must be tied to the scientific aims of the project
Carryover reflected on NoA($50k TC carryover; original award of $250k TC)
Offset Unobligated funds used to “partially pay”
the current fiscal year budget period When a grant is offset:
The approved budget DOES NOT increase or decrease
The total federal award amount DECREASES the current fiscal year’s dollars
May use an offset due to large unexplained unobligated balances or when the need for funds changes (such as a post-doc slot on a training grant going unfilled)
Offset reflected on NoA ($50K TC offset; $250K TC approved)
Prior Approvals Certain post-award actions require the
prior approval of the NIH Grants Management Officer
NIH Grants Policy Statement, 8.1.2 Prior Approval Requirements:
http://grants.nih.gov/grants/policy/nihgps_2012/nihgps_ch8.htm#prior_approval_requirements
Prior Approval All requests for prior approval must be:
Submitted in writing or via email – include complete grant number, PI name and contact information, grantee name
Submitted to the awarding IC’s Grants Management Specialist no later than 30 days before the proposed change
Signed by the AOROnly responses to prior approval requests
signed by the GMO are valid
Required Prior Approvals …
Alterations and renovations Capital expenditures Addition of a foreign component Preaward Costs >90 days prior to effective
date of new or competing award Deviation from award terms and conditions Changes in grantee organizational status
Required Prior Approvals …
Transferring of funds between construction and nonconstruction work
Retention of research grant salary/fringe benefit funds when a K Award is made
Transferring amounts from trainee costs Second no-cost extension or extension >
12 months
Required Prior Approvals …
Need for additional NIH funds—aka supplement
Carryover of unobligated balances Change in scope Change in key personnel named in
NGA Change in grantee Institution
Requests for additional funding: Revision Application (Type 3)(formerly a competing supplement)
Supports an expansion in scope of the research
Peer-reviewed and council review Standard application dates at:http://grants.nih.gov/grants/funding/submissionschedule.htm
Requests for additional funding: Administrative Supplement To meet increased costs within the
original scope of the research Provide funds for unanticipated costs not
included in competitive application Provide funds for special populations to
enter or re-enter biomedical research Requires prior approval Limited $/requires exceptional justification
Administrative Supplement – New - Electronic Submission
Administrative Supplements to Existing NIH Grants and Cooperative Agreements, PA-12-100 - February 8, 2012
http://grants.nih.gov/grants/guide/pa-files/PA-12-100.html
For grants with activity codes that have transitioned to electronic submission using the SF424 (R&R) application forms, requests may be submitted electronically through grants.gov
Other activity codes still use paper-based PHS398 application forms
Prior Approval Change in scope:
Grantee makes initial determination of significance of a change, consulting the Grants Management Specialist as needed.
The following items may indicate a change in scope: Change in aims Significant rebudgeting (deviation between
categories of more than 25% of total awarded costs)
Change in use of animals or humans Significant change in key personnel Shift in research emphasis Application of new technology
Refer to NIH Grants Policy Statement for further information
Prior Approval Change in status, including absence, of
PD/PI and other Senior/Key Personnel named in NoA:Grantee must notify NIH if individual will:
Reduce his/her time by 25% or more of effort level approved at time of award
Withdraw from the project Be absent for 3 or more months This is only for key personnel named in the NoA,
NOT for key personnel designated in the application (our key not yours)
Prior Approval Change in status, including absence, of
PD/PI and other Senior/Key Personnel named in NoA (continued): Prior approval must be from NIH for the replacement
of the PI Request should include:
Justification for the change Biographical sketch of the individual proposed Other sources of support Budget changes resulting from the change Human Subject Education Certification (if
applicable)
Prior Approval Change of Grantee Institution (Transfer)
Grants Policy Statement, 8.1.2.7 Change of Grantee Organization
http://grants.nih.gov/grants/policy/nihgps_2012/nihgps_ch8.htm#_Toc271264936
Original grantee must complete:Relinquishing StatementFinal Federal Financial Report and Final
Invention Statement
Relinquishing Statement PHS 3734
An ESTIMATE of amount relinquished Do not include unobligated balance from prior
years: it will transfer automatically
Prior Approval/Transfer Proposed new grantee must complete:
Application w/ face page Budget (current and future years) based on Direct
Costs committed/relinquished Updated biosketches for PD/PI and senior/key
personnel (existing and proposed new) Updated resources statement Progress report (for transfer on anniversary date) Statement whether research plans/aims have
changed from original submission New IRB/IACUCs List of equipment purchased with grant funds to
transfer to new organization
Prior Approval /Transfer Trouble spots?
The PI is moving… TOMORROW (or MOVED A
MONTH AGO)!!!The PI is relocating to WHERE?Establishing consortiumRelinquishing Statement delaysEquipmentFinal Federal Financial Report from original
grantee
Change of Institution– New - Electronic Submission
Change of Grantee Organization, PA-12-270–August 24, 2012
http://grants.nih.gov/grants/guide/pa-files/PA-12-270.html
Electronic submission not yet required, but highly recommended
Unless instructed by awarding IC, budgets are limited to direct costs relinquished by the original institution, plus applicable F&A costs for the new institution
Closeout: Final Reports Final Progress Report Final Invention Statement Final Federal Financial Report (FFR)
Failure to submit timely and accurate closeout reports may affect future funding!
90-day requirement is a term and condition of NIH grant awards
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Select Resources at the NIHGrants Management Specialist on NGA- If unknown, contact Chief GMO of IChttp://grants2.nih.gov/grants/stafflist_gmos.htm
Program Official on NGA
Division of Financial Advisory Services http://oamp.od.nih.gov/dfas/dfas.asp
Office of Extramural Researchhttp://grants.nih.gov/grants/oer.htm
NIH Grants Policy Inbox (policy questions not specific to NGA)[email protected]
NIH Helpdesk (technical questions)[email protected] or http://support.nih.gov/
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More Resources at the NIHNIH Grants Compliance and Oversight – website has compendium of observations, and presentationshttp://grants1.nih.gov/grants/compliance/compliance.htm
NIH Outreach Activities and Resourceshttp://grants1.nih.gov/grants/outreach.htm
NIH Grants Policy Statement (10/12): http://grants.nih.gov/grants/policy/nihgps_2012/index.htm
PHS 398 Application (form pages are PDF-fillable): http://grants1.nih.gov/grants/funding/phs398/phs398.html
PHS2590 Progress Report (form pages are PDF-fillable): http://grants.nih.gov/grants/funding/2590/2590.htm
Questions??