THEN WHAT Rebecca D Claycamp MS CRA Chief Grants Management Officer National Institute of Mental Health NIH Terri Jarosik Supervisory Grants Management Specialist National Institute of Mental Health NIH ID: 724477
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After the Award is Made…THEN WHAT?
Rebecca D. Claycamp, MS, CRA
Chief Grants Management Officer
National Institute of Mental Health, NIH
Terri Jarosik
Supervisory Grants Management Specialist
National Institute of Mental Health, NIH
JUNE 2012Slide2
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
CloseoutSlide3
Notice of Award (NoA) What is the Notice of Award letter? What are the components of the NoA letter?
Grantee acceptance of awardSlide4
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 StatusSlide5Slide6
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 InformationOIG Hotline InformationOther terms/info that apply to all awards
Components of the
NoASlide7
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 StatementSlide8
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.govSlide9
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 IncomeSlide10
Components of the NoA (continued)
NoA
Section IV: IC Special Terms and Conditions
Cooperative Agreement
Restrictive terms
Information items
Staff Contact Information
Spreadsheet SummarySlide11Slide12
Grantee AcceptanceThe grantee indicates acceptance of the terms and conditions of the award by
drawing down funds
from the Payment Management SystemSlide13
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
Slide14
Progress ReportsSNAP or Non-SNAP
Elements of a Progress Report
How to submit
When to submitSlide15
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_2012/nihgps_ch8.htm#_Toc271264971
Detailed budgets not required
Federal Financial Report due at end of competing segment
eSNAP
retiring, RPPR requiredSlide16
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-13-061Slide17
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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17Slide18
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.
BudgetAre there still the three questions?Slide19
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 fundsSlide20
Submitting a SNAP Progress ReportElectronically via eRA Commons, 45 days before next budget start date
Commons-registered institutions and PIs:
D
ue 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.jspSlide21
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 TBDSlide22
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 PageAt committed level with written justification
Updated Other
Support
Progress Report Summary
Checklist
All Personnel Report Slide23
How to submit a 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) 594-6584Slide24
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.Slide25
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%)Slide26
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 reportsSlide27
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 FFRIn the eRA Commons (Federal Cash Transaction Reporting completed in Payment Management System on the FFR using cash transaction data elements)Slide28
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 Reports
http://grants.nih.gov/grants/policy/nihgps_2012/nihgps_ch8.htm#_Toc271264973
Slide29
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 Slide30
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 projectSlide31
Carryover reflected on NoA($50k TC carryover; original award of $250k TC)
Slide32
OffsetUnobligated 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)Slide33
Offset reflected on NoA ($50K TC offset; $250K TC approved)
Slide34
Prior ApprovalsCertain 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
Slide35
Prior ApprovalAll 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 AOR
Only responses to prior approval requests signed by the GMO are validSlide36
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 statusSlide37
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 monthsSlide38
Required Prior Approvals …Need for additional NIH funds—aka supplementCarryover of unobligated balances
Change in scope
Change in key personnel named in NGA
Change in grantee InstitutionSlide39
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
Slide40
Requests for additional funding: Administrative SupplementTo 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 justificationSlide41
Administrative Supplement – New - Electronic SubmissionAdministrative 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 Slide42
Prior ApprovalChange 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 humansSignificant change in key personnelShift in research emphasisApplication of new technology
Refer to NIH Grants Policy Statement for further informationSlide43
Prior ApprovalChange 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) Slide44
Prior ApprovalChange 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)Slide45
Prior ApprovalChange 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 Statement
Final Federal Financial Report and Final Invention StatementSlide46
Relinquishing Statement PHS 3734An ESTIMATE of amount relinquishedDo not include
unobligated
balance from prior
years: it will transfer automaticallySlide47
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 organizationSlide48
Prior Approval /TransferTrouble spots?The PI is moving…
TOMORROW
(or MOVED A MONTH AGO)
!!!
The PI is relocating to WHERE?
Establishing consortium
Relinquishing Statement delays
Equipment
Final Federal Financial Report from original granteeSlide49
Change of Institution– New - Electronic SubmissionChange 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 institutionSlide50
Closeout: Final ReportsFinal Progress ReportFinal Invention StatementFinal 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 awardsSlide51
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Select Resources at the NIH
Grants Management Specialist on NGA
- If unknown, contact Chief GMO of IC
http://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 Research
http://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/
Slide52
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More
Resources at the NIH
NIH Grants Compliance and Oversight – website has compendium of observations, and presentations
http
://grants1.nih.gov/grants/compliance/compliance.htm
NIH Outreach Activities and Resources
http
://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
Slide53
Questions??