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After the Award is Made… THEN WHAT?. Grace Olascoaga Chief, Grants Management Officer Grants Administration Branch National Institute of General Medical Sciences (NIGMS ). After the Award: The Grants Management Perspective. Topics of Discussion. Notice of Award (NoA) Progress Report
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After the Award is Made…THENWHAT? Grace Olascoaga Chief, Grants Management Officer Grants Administration Branch National Institute of General Medical Sciences (NIGMS)
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 funding Revision application (competing) Administrative supplement Closeout The 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
Components of the NoA (continued) NoA Section III: Terms & Conditions 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
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
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 Requirements 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 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 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 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? (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 PI Two months prior to the due date Two 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 http://grants.nih.gov/grants/policy/nihgps_2010/nihgps_ch8.htm#_Toc271264973
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 approvedbudget 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.
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 extension Change in status of PD/PI or Senior/Key Personnel or grantee organization status Change of grantee institution Pre-award costs more than 90 days (competing grant)
Prior Approval Examples (continued): Addition of a foreign component Carryover of unobligated balances Undertaking activities disapproved or restricted as a term of award Change 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 institution • Grants Policy Statement, 8.1.2.7 Change of Grantee Organization http://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 institution • Application 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 consortium • Relinquishing Statement • Equipment • Final 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