After the Award: Program (Scientific) Perspective ************* Harold

advertisement
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
 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
Components of the NoA
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
(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/nih
gps_ch8.htm#_Toc271264971



Detailed budgets not required
Federal Financial Report due at end of
competing segment
THREE RESPONSES:
SNAP Administrative & Fiscal Requirements
1.
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




Budget Page




FWAs/Assurances
IRB/IACUC dates
Education Certification for new personnel
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 NonCompeting 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 SF272/SF-272A) into a single form known as
the Federal Financial Report (FFR or SF425/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 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/n
ihgps_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:
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
 Submitted
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
Failure to submit timely and accurate
closeout reports may affect future funding!

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
http://grants.nih.gov/grants/policy/nihgps_2010/nihgps_ch8.htm#
_Toc271264983
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??
Download