after the award is made…then what? grace olascoaga chief, grants management officer grants...

After the Award is Made…THEN WHAT?

Grace OlascoagaChief, Grants Management OfficerGrants Administration BranchNational Institute of General Medical Sciences (NIGMS)

After the Award:The Grants Management Perspective

Topics of Discussion Notice of Award (NoA) Progress Report

SNAP (Streamlined Non-competing Award Process)

Non-SNAP (categorical) Federal Financial Report (including Financial Status

Report info)

Carryovers & Offsets Prior Approvals (including change of grantee

institution)

Topics of Discussion (continued)

Requests for additional fundingRevision application (competing)Administrative supplement

CloseoutThe process

Questions

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 Sent to the business official (e-mailed) 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



Also (some dependent on award characteristics):

ARRA Terms 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



Requirements for DUNS # and CCR registration Transparency Act Multi-Year Funded Public Access Closeout term (when applicable) Co-funding (when applicable) Program Income


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

Progress Reports

SNAP or Non-SNAP Elements of a Progress Report How to submit Timeliness

Key Elements of the Progress Report

Face Page (Non-SNAP) Budget and justification (Non-SNAP) Biosketch Other Support (Non-SNAP) Progress Report Summary Checklist page (Non-SNAP) All Personnel Report

SNAP Progress Reports - Administrative & Fiscal Requirements

Grants Policy Statement, 8.4.1.2 Streamlined Non-Competing Award Process

http://grants.nih.gov/grants/policy/nihgps_2010/nihgps_ch8.htm#_Toc271264971

Detailed budgets not required Federal Financial Report due at end of

competing segment THREE RESPONSES:

SNAP Administrative & Fiscal Requirements1. Has there been change in the 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

2. Will there be, in the next budget period, a significant change in the level of effort for the PD/PI or other personnel designated on the Notice of Grant Award from what was approved for this project?

Describe any significant change (25% or greater reduction) in the level of effort of key personnel named in the Notice of Award

3. 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

Non-SNAP Progress Reports -Administrative and Fiscal Requirements

Submit complete non-competing continuation application (PHS 2590) 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 (electronic

submission)

Non-SNAP Progress Reports -Administrative and Fiscal Requirements (continued)

Face Page Correct contact information Human Subjects/Animals

FWAs/Assurances IRB/IACUC dates Education Certification for new personnel

Budget Page AT COMMITTED LEVEL Written justification

Updated Other Support Checklist page

How to submit SNAP Progress Report Electronically via eRA Commons, 45 days

before next budget start date Commons-registered institutions and PIs:

Have access to due date information 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

How to submit Non-SNAP Progress ReportHard 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? (continued) Lack of or slow response to inquiries Info sent without identification—always include

grant number Missing counter-signature of an authorized

business official Budgets with inadequate justification Other Support for an individual that exceeds

100%

What Can Delay the Award Process?

Missing information for Key Personnel Out-of-date IRB/IACUC approvals Lack of population data for clinical trials

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 dateTwo weeks after the due date for overdue

reports

Federal Financial Report (including Financial Status Report info)

The Office of Management and Budget has consolidated the Financial Status Report (FSR or SF-269/SF-269A) and the Federal Cash Transaction Report (FCTR or SF-272/SF-272A) into a single form known as the Federal Financial Report (FFR or SF-425/SF-425A)

Federal Financial Report (including Financial Status Report info) (continued)

Beginning 2/1/2011 NIH implemented the expenditure data portion (i.e., FSR info) of the FFR in the eRA Commons

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

(Federal CashTransaction Reporting completed in Payment Management System on the FFR using cash transaction data elements)

Federal Financial Report (including Financial Status Report info) (continued)

Expenditure data and Cash Transaction data on the final FFR must reconcile

MUST 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

Grants Policy Statement, 8.4.1.4 Financial Reports


Carryover/Offset – What’s the Difference?

One increases the approved budget

and the other… Decreases the current fiscal year’s dollars

by “partially paying” the current year’s grant with funds from a prior year

Carryover/Offset

FIRST: YOU MUST HAVE AN UNOBLIGATED BALANCE

Unobligated Balance: Definition: Amount indicated on the Federal Financial

Report (FFR) that represents funds the grantee institution was awarded but has not obligated (spent).

The amount listed as “unobligated funds” on the FFRshould include any funds that remain restricted from use in prior years/budget periods. This is a cumulative amount and should never decrease unless there has been a carryover or partial payment (offset).

Carryover Unobligated funds that are carried forward from one fiscal year

or budget period to another. For grants not subject to automatic carryover, this action

requires a written request from the grantee (countersigned by the institution’s authorized business official), including a detailed budget page and budget justification.

The budget page should reflect both Direct costs and F&A costs.

The approved budget is increased on the NoA allowing the grantee to spend funds carried forward from the previous fiscal year/budget period.

The Total Federal Award Amount remains unchanged, (must reflect $0), since funds are carried forward from a previous fiscal year as opposed to adding funds, (new $$).

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 However, the Total Federal Award Amount

DECREASES the current fiscal year’s dollars… indicating that the Approved Budget will be ‘partially paid’ with funds from a prior fiscal year.

Offset reflected on NoA ($50k TC offset; $250k TC approved)

Prior Approval

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://odoerdb2.od.nih.gov/gmac/nihgps_2010/nihgps_ch8.htm#prior_approval_requirements

Prior Approval

Examples of actions requiring NIH Prior Approval:No-Cost Extensions beyond first extensionChange in status of PD/PI or Senior/Key

Personnel or grantee organization statusChange of grantee institutionPre-award costs more than 90 days

(competing grant)

Prior Approval

Examples (continued):Addition of a foreign componentCarryover of unobligated balancesUndertaking activities disapproved or

restricted as a term of awardChange in scope

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 more than 25% of effort level

approved at time of award Withdraw from the project Be absent for 3 or more months

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 institutionGrants Policy Statement, 8.1.2.7 Change of

Grantee Organizationhttp://grants.nih.gov/grants/policy/nihgps_2010/

nihgps_ch8.htm#_Change_of_Grantee

Prior Approval (change of grantee institution)

Original grantee must complete:

Official Statement Relinquishing Interests and Rights in a PHS Research Grant (PHS 3734)

final Federal Financial Report and Final Invention Statement

Prior Approval (change of grantee institution) Proposed new grantee must complete:

Request for change of institutionApplication includes:

Face page Budget (current and future years) based on Direct

Costs committed Updated biosketches for PD/PI and senior/key

personnel (existing and proposed new) Progress report (for transfer on anniversary date) Statement whether research plans/aims have

changed from original submission

Prior Approval (change of grantee institution)(continued)

Application includes: Updated “other support” Resources page, including effect of move on

project Checklist page Certification of IRB/IACUC approvals, assurance

numbers List of equipment purchased with grant funds to

transfer to new organization (this list indicates acceptance of title)

Prior Approval (change of grantee institution)

Troublespots?The PI is moving… TOMORROW (or MOVED A

MONTH AGO)!!!The PI is relocating to WHERE?Establishing consortiumRelinquishing StatementEquipmentFinal Federal Financial Report from original

grantee

Relinquishing Statement PHS 3734

An ESTIMATE Do not include Carryover (unobligated balance

from prior years)

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 administrative official Only responses to prior approval requests signed by the

GMO are valid

Requests for additional funding: Revision Application

Only to support an expansion in scope of the research

Received 3 times a year and are peer-reviewed by both a study section and council

Requests for additional funding: Administrative Supplement To meet increased costs within the scope of

the research, unforeseen when competing application or progress report was submitted

Must be submitted directly to the IC with a complete and detailed budget and a written justification

Requires Prior Approval

CLOSEOUT: Final Reports

Final Federal Financial Report (FFR) REMEMBER, cash transaction and expenditure data must

reconcile

Final Invention Statement and Certification Final Progress Report

Grants Policy Statement, 8.6 Closeout


Reminder

Failure to submit timely and accurate closeout reports may affect future

funding!

90-day requirement is a term and condition of NIH grant awards!

RESOURCE WEB LINKS Office of Extramural Research Grants Home Page:

http://grants.nih.gov/grants/oer.htm

NIH Grants Policy Statement (10/10): http://odoerdb2.od.nih.gov/gmac/nihgps_2010/index.htm

NIH Guide: http://grants.nih.gov/grants/guide/index.html

PHS 398 Application (form pgs are PDF-fillable): http://grants1.nih.gov/grants/funding/phs398/phs398.html

PHS2590 Progress Report (form pgs are PDF-fillable): http://grants.nih.gov/grants/funding/2590/2590.htm

Types of Grant Programs:http://grants.nih.gov/grants/funding/funding_program.htm

Questions??Questions??

after the award is made…then what? grace olascoaga chief, grants management officer grants...

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