Dec 29, 2015
10. Grant Closeout and Final Report
9. Inventions
8. Audits
7. Federal Financial Report
4. Essentials of Grants Management
3. Disbursement of Funds
2. Notice of Award
1. Learning Objectives
Contents
5. Subcontracts 11. Resources
6. Annual Progress Report
1. List the important components of the Notice of Award (NoA)
2. Know where to go for grants management assistance
3. Identify strategies for successful grants management
4. Create a plan for managing subcontracts
5. Understand reporting requirements
6. Understand grant closeout process
Individuals completing this tutorial will be able to:
Learning Objectives
• The NoA notifies the grantee that an award has been made.
• The NoA is sent to the Business Office via email and is available in the eRA Commons.
• The award is made to the institution and not to the principal investigator(s).
• The grantee indicates acceptance of the NoA and its associated terms and conditions by drawing down funds from the grant.
Grantee notification
Notice of Award
• The NoA is issued for the initial budget period and each subsequent budget period in the approved project period.
• The NoA reflects any future-year commitments.
• Until an Institute or Center has issued the NoA for the initial award, any costs incurred by the applicant for the project are incurred at the applicant’s own risk.
Budget period
Notice of Award
• The NoA identifies:
• Grant Number
• PI and Grantee Institution
• Project Title
• Period of Support
• Funding Detail
• Federal Policy (Rules & Regulations)
• Terms and Conditions
• Helpful Websites
• NIH Contact Information
NoA contents
Notice of Award
• Award recipient acknowledgement
• Amount
• Name of institution
• What grantee’s acceptance entails
• Terms of acceptance
• Cause of Delays
• Lack of or slow response to inquiries
• Late submission of required documentation
• Incomplete/inaccurate documentation submission
• Inadequate justifications
• Assurances
Award recipient acknowledgement and cause of delays
Notice of Award
• Applicable if incurred within 90 days before effective date of award
• Must be necessary to conduct project
• Must be allowable event without prior approval
Pre-Award costs
Notice of Award
Which of the following is correct about the Notice of Award (NoA)?
A: _____ The NoA is the legal document issued to notify the grantee that an award has been made.
B: _____ Grantee indicates acceptance of NIH award by completing a PHS 2950 form.
C: _____ Once an NoA has been issued, it cannot be rejected by the awardee.
D: _____ The NoA includes the project period but not the budget start and end dates.
E: _____ NIH will always cover project costs incurred by the applicant before the NoA has been issued.
Self-assessment question
Notice of Award
A. The NoA is the legal document issued to notify the grantee that an award has been made.
Self-assessment answer
Pre-Award Issues
• Funds are requested electronically through Division of Payment Management’s Payment Management System (PMS).
• Delivered via Electronic Funds Transfer.
• Foreign awards are no longer paid on predetermined, quarterly advance basis.
• Payment can be requested as often as needed, but must accommodate only immediate needs.
Payments
Disbursement of Funds
• Foreign grantees must register in PMS by submitting the required forms to PMS after an award is issued.
• Required forms:
• PMS System Access Form for each PMS user
• Direct Deposit Sign-Up Form (SF-1199A)
• Forms are required for each organization if it does not have a PMS account for HHS awards or if the organization has a PMS account, but there is a change in the banking information.
Payments
Disbursement of Funds
• Foreign grantees are strongly encouraged to use U.S. banks or banks with U.S. branches, which helps ensure that payments arrive on time.
• The requirement for grantees to maintain grant funds in an interest bearing account is unchanged. See NIH Grants Policy Statement Section 6.3 Interest Earned on Advances of Grant Funds.
• Interest earned in excess of $250 per year in the aggregate on advances of Federal funds must be returned in U.S. dollars by reimbursement check.
Payments
Disbursement of Funds
• The principal investigator (PI) directs the project or program to be supported by the award. He or she is responsible and accountable to the grantee for the proper conduct of the project or activity.
• Additional responsibilities include:
• Making sure the goals approved in the grant application are achieved
• Managing the awarded funds
• Ensuring proper documentation that is compliant with federal laws and NIH policies and procedures
• Protecting the rights, safety, and welfare of research subjects
Essentials of Grants Management
• A grant is made to the institution not to the individual PI(s).
• The institution also is responsible for compliance with the terms and conditions of the award.
• For NIH grants: All official communication regarding the award is made between NIH staff and the Authorized Organizational Representative or Business/Signing Official.
Role of the Institution
Essentials of Grants Management
Which of the following is NOT a responsibility of the principal investigator (PI)?
A: _____ Ensures proper documentation as required by the federal regulations
B: _____ Manages the design, conduct, and reporting of the research project
C: _____ Protects the rights, safety, and welfare of research subjects
D: _____ Determines exemptions to the IRB study proposal review
Self-assessment question
Roles and Responsibilities of Principal Investigator
D. The principal investigator (PI) is not responsible for determining exemptions to the IRB study proposal review.
Self-assessment answer
Roles and Responsibilities of Principal Investigator
• Accomplish program goals set in the application
• Only use budget for activities within the approved scope of work with the approved budget amount
Goals for financial management
Essentials of Grants Management
• Federal Laws
• HHS Regulations
• NIH Regulations
• Program Announcement (PA)
• NIH GPS (Grants Policy Statement)
• Award Terms and Conditions
• OMB Circular A-21
Guidelines for successful grants management
Essentials of Grants Management
• Request prior approval when required
• Monitor expenditures
• Direct costs and facilities and administrative (F&A) costs
• No cost extensions
• Unallowable expenses
• Manage subcontracts
• Ensure compliance with reporting requirements
• Annual progress report
• Federal Financial Report
• Audits and Inventions
• Grants closeout and Final Report
Strategies for successful grants management
Essentials of Grants Management
• Refers to those actions and related costs that must not be carried out or incurred without written approval from NIH
• Presents a compliance issue—non-compliance leads to adverse actions and disallowed costs
• Requests must be submitted in writing to Grants Management Officer at least 30 days prior to change
Prior approval: What is it?
Essentials of Grants Management
• Prior approval is not required to re-budget funds for any direct cost item unless the incurrence of costs is associated with or is considered to be a change of scope.
• Any question about the need for prior approval for an activity or cost under a specific NIH award should be directed to your grant management officer.
Prior approval
Essentials of Grants Management
NIH prior approval is required for:
Under the following circumstances:
Alterations and Renovations (A&R)
Rebudgeting into A&R costs that would exceed 25 percent of the total approved budget for a budget period.
If rebudgeting would not meet this threshold but would result in a change in scope.
Any single A&R project exceeding $300,000.Capital expenditures (construction, land, or building acquisition)
All instances when purchase proposed; any proposal to convey, transfer, assign, mortgage, lease, or in any other manner encumber real property acquired with NIH grant funds.
Change in scope All instances
Changes in status of key personnel
Withdrawal from the project; absence for any continuous period of 3 months or more; reduction of time devoted to project by 25 percent or more from level in approved application.
Change of grantee organization All instances
Prior approval action summary
Essentials of Grants Management
NIH prior approval is required for:
Under the following circumstances:
Carryover of unobligated balances
If the NGA indicates that the grantee does not have the authority to automatically carry over balances.
Deviation from award terms and conditions
All instances. Includes undertaking any activities disapproved or restricted as a condition of the award.
Foreign component added to a grant to a domestic organization
All instances.
Need for additionalNIH funding
All instances, including extension of a final budget period of a project period with additional funds.
Pre-award costs More than 90 days before effective date of the initial budget period of a new or competing continuation award, at grantee’s own risk.
Prior approval action summary
Essentials of Grants Management
NIH prior approval is required for:
Under the following circumstances:
Retention of research grant funds when K award made
All instances.
Second no-cost extension or extension greater than 12 months
All instances.
Transfer of funds between construction and nonconstruction work
All instances.
Transferring amounts from trainee costs
All instances.
Prior approval action summary
Essentials of Grants Management
For more information, see NIH Grants Policy Statement: Prior-Approval Requirements.
Which of the following does not require prior approval?
A: _____ Change in scope
B: _____ Second no cost extension
C: _____ Re-budget funds for a direct cost
D: _____ A $400,000 A&R project
E: _____ A key personnel member is absent for 4 months
Self-assessment question
Financial Management
C. Re-budget funds for a direct cost does not require prior approval.
Self-assessment answer
Financial Management
Ensures that:
• Actual expenses are periodically compared with original budget
• Actual expenses are accurate (reasonable, allocable, allowable, necessary, consistently charged)
• Mischarges are corrected in timely manner
• Prior approvals are obtained
• Sub-recipient expenses are monitored
Monitoring expenditures
Essentials of Grants Management
• All direct costs must be:
• Reasonable: generally recognized as ordinary and necessary
• Allocable: incurred specifically for grant and can be charged to line item within the budget; incurred to perform the work of the award
• Allowable: legal, necessary for performance of grant agreement, not included as charge to other projects in current budget period; be adequately documented
• Consistently applied: costs are assigned to cost objectives consistently; is considered normal for that type of grantee
Monitoring expenditures
Essentials of Grants Management
• NIH provides limited F&A costs (8 percent of total direct costs less only equipment) to foreign institutions and international organizations to support the costs of compliance with NIH requirements
• Examples of compliance requirements include protection of human subjects, animal welfare, invention reporting, other post-award reporting requirements, financial conflict of interest and research misconduct
• NIH will not support the acquisition of, or provide for depreciation on, any capital expenditures, or support the normal, general operations of foreign and international organizations. These expenses should not be requested as a Direct Cost budget expense
Facilities and Administrative (F&A) costs
Essentials of Grants Management
• 1st no cost extension: No prior approval required, up to 12 months, done through eRA Commons by institution
• 2nd no cost extension: Requires prior approval, explanation, scientific rationale and plan, categorical budget
• Mid-year no cost extension: Requires prior approval, explanation, categorical budget, budget and project periods are extended
Monitoring expenditures: No cost extensions
Essentials of Grants Management
• Use OMB Circular A-21, Section J, as reference tool
• Examples of unallowable expenses:
• Alcohol and entertainment
• Advertising/PR costs
• Commencement/convocation costs
• Pre-agreement costs
• Fines or penalties resulting from non-compliance
• Lobbying
• Memberships
Monitoring expenditures: Unallowable expenses
Essentials of Grants Management
Which costs below are considered allowable costs?
(You can choose more than one answer below)
A: _____ Costs of alcoholic beverages
B: _____ Service contracts for core equipment
C: _____ Fines and penalties resulting from violations of, or failure of the institution to comply with Federal, State, and local or foreign laws and regulations
D: _____ Personal living expenses
E: _____ Salary and fringe for staff
Self-assessment question
Essentials of Grants Management
B. and E. Service contracts for core equipment and salary and fringe for staff are considered allowable costs.
Self-assessment answer
Essentials of Grants Management
• In a collaboration, a grant is made to research partners, who develop a proposal together, conduct the research, and share in the credit for the resulting scientific advances and publications.
• This is different from a contractor/subcontractor relationship:
• A contract is an agreement between two or more parties that creates an obligation to perform a particular duty.
• The prime recipient is the organization/entity that is the direct recipient of the sponsor’s funds. The prime recipient assumes a number of responsibilities, including management of subcontracts.
• A subcontract is an agreement to perform work in support of a prime contract. Note that the NIH refers to a subcontract as a “consortium/contractual agreement,” but many people still use the term “subcontract.”
Subcontracts vs. collaborations
Subcontracts
The prime contractor (recipient of the grant)
• Determines and justifies the proportion of work to be done by the subcontractor
• Assesses and approves the contracting arrangements
• Remains accountable to the sponsor for the performance of the subcontractor
• Monitors the subcontractor’s progress
• Ensures that the subcontractor complies with the rules and regulations that were set and prepares written contractor agreements with the subcontractor
• Develops a surveillance plan—an organized written document used for quality assurance surveillance
Role of the prime contractor
Subcontracts
The prime contractor should be able to rely on the subcontractor to
• Provide specialized services
• Enhance operational capacity and competency
• Reduce exposure to specific risks inherent in the contract
• Maintain quality control (the prime contractor is responsible for quality assurance)
• Bear responsibility for programmatic decision making and measurable performance requirements as agreed
• Adhere to compliance requirements of the prime contract
Role of the subcontractor
Subcontracts
Indicate whether each item is the responsibility of the prime recipient or the subcontractor.
Quality assurance
Quality control
Accountability to the sponsor for performance on the grant
Development of surveillance plan
Responsibility for measurable performance requirements as agreed in consortium/contractual agreement
Self-assessment question
Subcontracts
Indicate whether each item is the responsibility of the prime recipient or the subcontractor.
Quality assurance prime recipient
Quality control subcontractor
Accountability to the sponsor for performance on the grant prime recipient
Development of surveillance plan prime recipient
Responsibility for measurable performance requirements as agreed in consortium/contractual agreement subcontractor
Self-assessment answers
Subcontracts
When writing a proposal, the prime contractor should keep the following in mind
• For NIH grant applications or other programs using NIH forms, a signed application face page and checklist from the subcontracting organization are required.
• For non-NIH applications, a signed letter of intent “to form a subcontract agreement” is required.
• A scope of work and contact information of the subcontractor might be required.
• When consortium/contractual agreements are involved, be sure to follow budget instructions carefully — for example, on how to calculate facilities and administrative (F&A) costs.
Proposal (grant application) process
Subcontracts
What is the NIH policy regarding foreign subcontractors and foreign grantees?
• Policy requirements “flow down.” A domestic institution administering a subcontract to a foreign institution must assure NIH that the prime contractor is holding its collaborator to the policies required for foreign institutions.
• Likewise, if the foreign grantee is the primary grantee, it must assure NIH that its American collaborator is following all the policies required for U.S. institutions.
• Prior to beginning work, the prime recipient and the subcontracting organization should
• Develop and implement a written subcontract agreement
• Develop a schedule and method for payments
• Set up communication systems to ensure that progress reports, financial status reports, and so forth are completed in a timely manner
Policy requirements “flow down” to subcontractors
Subcontracts
• There is transparency and clarity about which subcontractors are being used.
• Formal agreements between the prime and subcontractors are made.
• Subcontractors have a high degree of awareness of the prime contractor’s methods of working and the granting institution’s expectations.
• Subcontractors are allowed to attend grantor-contractor progress meetings.
• Subcontractors are encouraged and rewarded for innovation
• Formal procedures are in place for subcontractor selection, quality assurance, monitoring performance, and so on.
• The prime contractor receives copies of subcontractor progress meeting summaries and post-inspection reports.
Characteristics of effective subcontracting arrangements
Subcontracts
Depending on the services the subcontractor is to provide, the parties may need to reach agreement on the following points
• Scientific and administrative aspects of the consortium/contractual agreement (policies and procedures; sample and data storage—where, for how long, and sample disposal and data retention)
• Biological samples (material transfer agreements [MTAs], storage, and future use)
• Data management plans
Records and data management
Subcontracts
The prime recipient and the subcontractor must
• Have separate bank accounts for the grant
• Maintain accounts that allow electronic transfer of funds
• Decide how payments will be initiated, authorized, and approved
• Set up authorized signatories (preferably two)
• Comply with the financial guidelines of the local institution, the granting organization, and the study sponsor
Note that foreign recipients of NIH grant funds are subject to the same audit requirements as for-profit organizations.
Banking and payment arrangements
Subcontracts
• Subcontractor fails to meet the requirements of the agreement (or is not fully aware of the requirements).
• Payment terms enjoyed by contractors are not passed on to subcontractors or as agreed to in the provisions.
• Performance management and evaluation of subcontractors is weak.
• Relationships between contractors and subcontractors are largely informal.
• There is bias in subcontractor selection.
• There are compliance issues with special terms and conditions of the sponsor and as required by the prime in the subcontract provision.
Challenges in subcontract agreements
Subcontracts
Dr. Jones is the prime recipient of an NIH grant. He is a professor of medicine at the University of Chicago in the United States. Dr. Smythe is a subcontractor for the research. She is a professor at a foreign institution.
Self-assessment question
Subcontracts
Dr. Smythe: In our region, it is acceptable to label research samples with the participant’s full name and date of birth. That way, it is easy to check the information to avoid mix-ups in the lab.
Who is correct and why?
Dr. Jones: As we outlined in our consortium/contractual agreement, research samples should be labeled using a code to protect the privacy of study participants.
Because Dr. Jones is the prime recipient of NIH grant funding, policy requirements regarding privacy protections “flow down” to the subcontracting organization; the sample data should be coded to protect participants’ privacy,
Self-assessment answer
Subcontracts
• PI should keep track of the dates when annual progress reports are due
• PI should check that the business office has sent progress report to NIH
• Find a list of your institution’s due progress reports in the eRA Commons: Progress Report Search By IPF Number
• Search Institutional Profile File (IPF) number using the IPF Number Search
• Run a Progress Report Search by IPF Number
Timely submission is key
Annual Progress Report
• Non-SNAP: Non-Competing Continuation Progress Report PHS 2590
• Due 2 months prior to anniversary date (beginning of next budget period)
• Use the online instructions and form pages
• Submit to centralized address (found in terms of award), not directly to the Institute or Center
• Serves as official request for funding
• Most recent institutional review board (IRB) and Institutional Animal Care and Use Committee (IACUC) approval dates required
Annual Progress Report
Types of progress reports for NIH: Paper
• Streamlined Non-competing Award Process (SNAP) is submitted through new Research Performance Progress Report (RPPR) module located in eRA Commons
• Due on the 15th of the month preceding the month in which the budget period ends
• IRB and IACUC approval dates not required but available upon request
• Grantee may delegate authority to PD/PI to submit progress report directly
• No detailed budget information submitted
Annual Progress Report
Types of progress reports for NIH: Electronic
Information current as of September 2013. Please see NIH websites for updates on policies and procedures.
• Program officer—to ensure sufficient progress has been made to justify continued funding
• Grants management specialists—to provide administrative and sometimes fiscal evaluation
Who reviews the report?
Annual Progress Report
• Your evaluation of how the project is going
• Any changes or proposed changes in the scope, goals, or objectives of the project
• Any changes in key personnel
• Any evidence of scientific overlap
• Gender and minority information for human subjects
• Human subject enrollment tables, if required
• Any changes or concerns regarding human subjects or animal research
• Changes in any other type of support
Assessment of progress
Annual Progress Report
• All investigators funded by the NIH must submit to the National Library of Medicine’s PubMed Central an electronic version of their final, peer-reviewed manuscripts immediately upon acceptance for publication.
• Publications must be made publicly available no later than 12 months after the official date of publication.
• NIH will delay processing of an award if publications arising from are not in compliance with the NIH public access policy.
A Word about public access
Annual Progress Report
• Cover Page
• Accomplishments
• Products: Publications, websites, and inventions
• Participants: Project personnel
• Impact on physical, institutional, or information resources
• Changes
• Special Reporting Requirements: human subjects enrollment, foreign components, and unobligated balances
Annual Progress Report
Components of SNAP Reports in RPPR Module
• Face page
• Detailed budget page
• Budget justification
• Progress report summary
• Checklist
• All personnel report
• Other support
See NIH website for more information on PHS 2590 forms, including downloadable instructions and fillable forms.
PHS 2590 Forms for Non-SNAP Reports
Annual Progress Report
• Pre-populated
• Available via the eRA Commons
• Grantee information is preprinted through item #5
• Check preprinted info and, if necessary, make corrections in section 12
Annual Progress Report
PHS 2590: Face page
• Direct costs requested must be itemized for the impending budget period.
• Use recommended direct costs shown on the NoA issued in the year as a guide for developing annual budget.
PHS 2590: Detailed budget
Annual Progress Report
• Provide a detailed budget justification for those line items and amounts that represent a significant change from that previously recommended.
• Explain estimated unobligated balance >25% of current year’s total approved budget
• Explain why there is a significant balance
• Describe how it will be used if carried forward to next budget period
PHS 2590: Budget justification
Annual Progress Report
• Complete biographical sketch for all new senior/key personnel since previous submission—limit to 4 pages each
• Include documentation of training in the protection of human subjects—for anyone involved in the design or conduct of human subjects research
PHS 2590: Biographical sketch
Annual Progress Report
• Think through the progress report carefully
• Include records of accomplishments—add value and provide basis for continued support
• Describe potential impacts of your findings to science and public health
• NIH will fund the next year only after approval of your progress report.
Non-SNAP progress report summary
Annual Progress Report
• Statement of expenditures reported against funds awarded
• Provides an effective mechanism to account for grants funds
What is the Federal Financial Report (FFR)?
Federal Financial Report
• Responsibility:
• Grantee’s Accounting Office submits the FFR
• PI must forward budget information to accounting office and follow up to ensure timely and accurate submission
• Electronic submission only, through eRA Commons
• Must be submitted in English and in U.S. dollars
• Submission reports must be timely and accurate
• Must use the currency rate in effect at the time the funds are drawn down from PMS.
Submission of FFR
Federal Financial Report
• NIH monitors financial aspects of grants using transaction information in PMS (required by foreign grants for payment)
• Foreign SNAP: Data required only at end of competitive period
• Must be submitted within 90 days after the end of the period
• Must report on cumulative support awarded for entire period
• Foreign Non-SNAP: Annual FFRs due within 90 days of the end of the quarter in which their budget period end date falls
Process
Federal Financial Report
• FFRs may be revised—OFM requires Grant Management approval for revisions submitted within 15 months after budget/project period end date
• Large balances should be reviewed/monitored
• Effective communication is key to overall success of the award
Things to remember
Federal Financial Report
• Arrange an annual audit if your institution spends $500,000 or more of HHS funds annually.
• Audits are conducted by an independent auditor, costs may be recovered using the 8% F&A costs.
Audits
Audit requirements
• Financial operations: must be properly conducted
• Financial reports: must be timely, fair, and accurate
• Compliance: must follow applicable laws, regulations, grant terms
• Resources: must be managed and used economically and efficiently
• Results and objectives: must be achieved effectively
What is reviewed?
Audits
• Subject to same audit requirements
• Provided with 2 options to satisfy audit requirements:
1. Financial-related audit of all HHS awards as defined in the Government Auditing Standards (Yellow Book)
OR
2. Audit that meets requirements of OMB Circular No. A-133
• Audits are conducted by independent auditor. Costs may be recovered as part of the 8% F&A costs.
Foreign grantees/organizations
Audits
1. Understand OMB A-133 audit requirements
2. Review project file once notification of audit
3. Identify a liaison
4. Request entry and exit meetings
5. Provide concise, truthful answers
6. Know avenues of resolution in case of conflict of interpretation with auditors
7. Keep leadership in the loop
Audits
Steps
• Must be submitted within specified time limits. Grantees have 30 days after receipt of auditor’s report or 9 months after end of the organization’s fiscal year, whichever comes first, to respond.
• Submit to:
National External Audit CenterHHS Office of Inspector GeneralHHS Office of Audit Services1100 Walnut Street, Suite 850Kansas City, Missouri 64106-2197 USA
Submission of audits
Audits
An audit is required for institutions in which of the following situations:
A: _____ Only when $500,000 or more HHS funds is received in one grant during a fiscal year
B: _____ Whenever an aggregate amount of $500,000 or more of HHS funds is received in a fiscal year
C: _____ Only when an aggregate amount of $1 million or more of HHS funds as well as from other sources is received in a fiscal year
D: _____ When any amount is received where no local institution audit arrangement exists
E: _____ At the end of the funding period
Self-assessment question
Audits
B. An audit is required for institutions whenever an aggregate amount of $500,000 or more of HHS funds is received in a fiscal year
Self-assessment answer
Audits
• Disclose an invention within 2 months of written disclosure by the inventor
• Provide grant, name of inventor, complete technical description
• Your business office sends this info through iEdison
• When applying for renewal or noncompeting support of grant, include either of the following:
• List of all inventions conceived or completed during preceding budget period
• Certification that no inventions were made during the period
Process for disclosure
Inventions
• Submit an annual Utilization Report upon receipt of a patent or when receiving royalties or a licensing fee from an invention that is not patented. Use iEdison to comply with reporting requirements.
• At the end of the project, submit a final invention statement and certification, HHS 568.
• See NIH Forms & Applications for more information.
Submissions
Inventions
• Foreign grantees have same rights and obligations regarding invention ownership as U.S. grantees
• Remember to:
• Report all subject inventions to NIH
• Make efforts to commercialize invention through patent or licensing
• Formally acknowledge Federal support in all patents
• Formally grant Federal government limited use license to invention
Inventions
Intellectual property
• Final report due 90 days after the project period end date
• Records kept accessible for 3 years after the grant ends. (Note: NIH requires 3 years, but some institutions may have longer requirements.)
• Closeout package: Submit through eRA Commons
• Includes three reports:
• Final Federal Financial Report
• Final Progress Report
• Final Invention Statement and Certification (see Inventions sections for more information)
Final report
Grant Closeout and Final Report
• Indicates exact balance of unobligated (unused) funds
• Provides an effective mechanism to account for grant funds
• May not reflect any unliquidated obligations (expenses agreed to but not paid)
• Must be submitted in English, using U.S. dollars, through eRA Commons
• See Grants Management Forms
Final Federal Financial Report (SF-425)
Grant Closeout and Final Report
• Statement of progress toward the original aims
• List of significant results, both positive and negative
• List of publications
• All investigators funded by the NIH must submit to the National Library of Medicine’s PubMed Central an electronic version of their final, peer-reviewed manuscripts upon acceptance for publication, to be made publicly available no later than 12 months after the official date of publication
• Report on the inclusion of gender and minority study subjects
• Description of data, research materials, or other information to be shared with other researchers
Final Progress Report
Grant Closeout and Final Report
• Needs to be included in the final financial report
• Covers property with an acquisition cost of $5,000 or more per unit
• Must include the following:
• Inventory list of all equipment purchased with grant funds
• Title to equipment usually vests with recipient or subrecipient
• Submit asset disposal plan per agency guidelines
Equipment report
Grant Closeout and Final Report
• Encumbrances and commitments
• Determine which need to be closed and which need to be filled
• Termination of personnel contracts
• Institution follows policies and procedures for terminations
• Staff not terminated need to be transferred to a new project
• Delays may result in unrecoverable costs that may not be charged to the grant
• Prohibit large orders during the last few months
• If orders have not been completed before the grant expires, contact vendors to either cancel the order or determine whether the delivery day will occur during the closeout period.
Tips for closeout
Grant Closeout and Final Report
• eRA Commons
• Payment Management System (PMS)
• NIH Grants Policy Statement
• OMB Circular A-133
• Government Auditing Standards (Yellow Book)
• United States Patent and Trademark Office
• United States Copyright Office
• NIH Public Access Policy
Resources
Helpful websites