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)grantspolicy@mail.nih.gov

NIH Helpdesk (technical questions)nihhelpdesk@mail.nih.gov 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??