Closeout of NIH Grants

1. Closeout of NIH Grants NCURA Region VI/VII Regional Meeting – Portland, OR Joe Ellis, Director Office of Policy for Extramural Research Administration

2. What is “Closeout” • Closeout is an “After-the-Award” activity officially ending the grant relationship. • Defined in 45 CFR Part 74.71 Closeout is the process in which the Federal awarding agency [NIH] determines that all applicable administrative actions and all required work with the award have been completed by the recipient [and NIH].

3. Closeout Basics • Recipients must submit all required financial, performance, and other reports as required by the grant. • Recipients must liquidate all obligations incurred under the award. • Agencies must make prompt payments for allowable, reimbursable grant costs Note: Closeout does not affect the right of an awarding agency to disallow costs and recover funds on the basis of later audits or other reviews.

4. NIH Closeout Requirements • Grantees must submit to NIH within 90 calendar days after the last day of the final budget period. • Final Progress Report • Final Financial Status Report • Final Invention Statement • Submit to eRA Commons (preferred) or NIH Centralized Processing Center • Requirements detailed in the NIH Grants Policy Statement • http://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part8.htm#_Toc54600151

5. Final Progress Report • No required form or standard format • Basic guidelines now provided in the PHS 2590 Progress Report Instructions. Include: • Statement of progress toward the original grant aims. • List of significant results (positive or negative). • List of publications. • If a competitive renewal (Type 2) has been submitted, whether funded or not, the progress report contained in that application may serve in lieu of a final progress report.

6. Final Progress Report (cont.) • Also include: • Report on the inclusion of gender and minority study subjects. • Where appropriate, indicate whether children were involved in the study or how the study was relevant for conditions affecting children. • Describe any data, research materials (such as cell lines, DNA probes, animal models), protocols, software, or other research information that is available to be shared and how it may be accessed. • Address any other specific requirements contained in the grant terms and conditions. See the PHS 2590 Instructions: grants.nih.gov/grants/funding/2590/2590.htm

7. Final Financial Status Report • Grantees will report using the Standard Form 269 – Financial Status Report • The SF 269 must indicate the exact balance of unobligated funds and may not reflect any unliquidated obligations. • There should be no discrepancies between the SF 269 and the Federal Cash Transaction Report (SF 272) • Do not submit an inaccurate or inaccurate FSR solely to meet the reporting deadline and then submit a revised report to correct it. Electronic submission is REQUIRED for FSRs

8. Final Invention Statement • Grantees will report using the HHS 568 Form – Final Invention Statement and Certification. • Must list all inventions first conceived or first actually reduced to practice during the course of work under the project. • Submission of the form is required even if inventions were previously reported to NIH. • If no inventions grantees must still submit a form reporting “none” • Not required for certain mechanisms such as training, educational, and construction grants (C06, R13, R25, S15, Ts, and Fs).

9. Electronic Closeout • NIH now offers electronic submission of all closeout documents. • NIH strongly encourages electronic submission • System allows grantees to track grants that are in closeout status. • Each report can be submitted separately • Electronic submission not yet mandatory for non-financial closeout documents but NIH continues to make progress toward that goal. • Available through the eRA Commons (http://commons.era.nih.gov). More at: http://era.nih.gov/files/grants_closeout2.pdf

10. Using the eRA Commons • Register your institution and PD/PIs in the Commons • Ensure the appropriate organizational official has the “FSR” role enabled in the Commons for financial reporting. • For grants with multiple PD/PIs, currently only the contact PD/PI can upload information into Commons. • Submission from the Commons to NIH can only be done by the signing official/AOO. • Contact the eRA Help Desk for assistance • Email: Commons@od.nih.gov • Phone: (866) 504-9552 More at: http://grants.nih.gov/grants/guide/notice-files/NOT-OD-05-051.html

11. NIH Centralized Processing Center • Office receives and processes reports submitted by U.S. mail, courier and overnight services, as well as by e-mail and fax. • All non-financial closeout documents not submitted through the eRA Commons must be submitted to the Center at: NIH Centralized Processing Center 6705 Rockledge Drive Room 2207, MSC 7987 Bethesda, MD 20892 (for regular/US Postal Service Express mail) Bethesda, MD 20817 (for other courier/express deliveries only) E-mail: DeasCentralized@od.nih.gov Fax: (301) 480-2304 More at: http://grants.nih.gov/grants/guide/notice-files/NOT-OD-08-061.html

12. Compliance Reminder • Failure to submit timely and accurate final reports may affect future funding to the organization and/or awards with the same PD/PI(s). Accordingly NIH may impose sanctions on institutions that fail to correct recurring problems. Sanctions may include: • Corrective Actions • Removal of Authorities • Delay or withholding of future awards to the project or program • Late closeout may extend the time period for retention of records since the 3-year record retention period is based on submission of the final FSR.

13. For More Information… • Grants Policy Interpretation & Consultation: • E-Mail: GrantsPolicy@mail.nih.gov • Phone: 301-435-0949 • Compliance Issues: • E-Mail: GrantsCompliance@mail.nih.gov • Phone: 301-435-0949 • Joe Ellis • E-mail: EllisJ@mail.nih.gov • Phone: 301-435-0935

14. Thank You! Any questions?