Purpose

The purpose of this Notice is to alert the NIH extramural community that NIH is strengthening enforcement of longstanding closeout requirements, outlined in the NIH Grants Policy Statement Section 8.6, Closeout. NIH has consistently reminded recipients of their responsibility to submit timely, accurate final grant expenditure reports, and has communicated the critical need for recipients to reconcile cash transaction reports submitted to the HHS Payment Management System (PMS) with expenditure reports submitted to NIH.  In order to fulfill agency requirements under the Grants Oversight and New Efficiency (GONE) Act and HHS grants policy, NIH will no longer delay the closeout of awards unless the recipient submits a prior approval request to the IC providing an acceptable written justification..  Without prior approval from the awarding IC, NIH will initiate unilateral closeout for all awards that fail to meet closeout requirements within 120 days as required by the NIH Grants Policy Statement (NIH GPS) Section 8.6. See below for details.

Background

Recipient Responsibilities

The requirement for timely closeout is generally a recipient responsibility. However, NIH may initiate unilateral closeout if a recipient does not provide timely, accurate closeout reports or does not respond timely to NIH requests to reconcile discrepancies in grant records.

NIH recipients must submit a Final Federal Financial Report (FFR), Final Research Performance Progress Report (F-RPPR), and Final Invention Statement and Certification (FIS) within 120 calendar days of the end of the period of performance (project period), as required in section 8.6 of the NIH GPS. The reports become overdue the day after the 120 calendar day period ends. Cash transaction data continues to be submitted directly to and processed by PMS. It is the recipient's responsibility to reconcile reports submitted to PMS and to the NIH awarding Institute or Center.

NIH Actions

NIH is committed to addressing and reducing grant closeout delays and to enhance compliance with HHS regulations and policies, and the GONE Act.  Therefore, NIH will strictly enforce its closeout policies. When recipients fail to submit timely reports, NIH will initiate unilateral closeout. It is important to note that for financial closeout, if a recipient fails to submit a final expenditure FFR, HHS policy directs NIH to close the grant using the last accepted Federal Cash Transaction Report’s cash drawdown amount. This could be considered a debt or result in disallowed costs.  In addition, failure to correct recurring reporting problems may cause NIH to take one or more actions that may include, but are not limited to, corrective actions, withholding of further awards, suspension or termination.

DATE:  November 15, 2017

TO:    Business Managers/Department Chairs/Center Directors/Faculty

FROM:Stan Jackson

RE:     OSP deadlines over the Winter Break, Dec. 23, 2017 – Jan. 1, 2018

________________________________________________________________

 This is a special announcement concerning the OSP schedule for reviewing/approving proposals with deadlines to federal and other agencies that occur during Winter Break this year. 

 Please note:

 All proposals with submission deadlines occurring between December 23, 2017 and January 1, 2018 must be fully routed, ready for submission, and released to the OSP office by the close of business on December 19, 2017; and: all proposals with submission deadlines occurring between January 2 - 3, 2018 (the first 2 business days after the break) will be due to OSP by the close of business on December 20 & 21, 2017, respectively.

 This schedule is consistent with our current policy, which requires the submission of complete proposals to OSP at least three business days before the agency submission deadline, since OSP will be closed during the Winter Break. 

 The campus closure during Winter Break will cause a heavy workload on OSP staff, so we will enforce our current policy more consistently.  Proposals received after the OSP deadlines specified above will be reviewed on a first come first serve basis and will be submitted only if time permits.  

Thank you for your understanding.

In preparation for the Business Managers Meeting on November 6, 2017, we are sponsoring a renaming contest.  Going forward, the last hour of the Business Managers Meeting is being designated for the Shared Services Centers Town Hall Meeting.   We also want the new name to be inviting to all interested attendees for topics pertinent to administrative professionals throughout campus. A $25 gift card will be awarded to the winning submission, so get your creative juices flowing!

The criteria for the renaming contest are as follows:

1.       Inclusive- The name needs to denote that all are welcome to attend.

2.       Creative- Think outside the box.

3.       Notable Acronym- Check the title you submit to verify that when changed into an acronym, it’s likeable and memorable.

All entries should be emailed to Desiree Stonesifer, at sdesiree@umbc.edu.  Entries should be submitted by November 3, 2017.  Following the meeting you will be able to vote for your name preference on the myUMBC Business Managers Meeting Group page.

If you have any questions please contact Desiree Stonesifer, at sdesiree@umbc.edu or 410-455-1642.

Desiree Stonesifer on behalf of Ben Lowenthal

There has (understandably) been considerable confusion about when to list personnel on a proposal as a Consultant or an Other Significant Contributor. First, let’s review a few definitions from NIH:

Senior/Key Personnel: The PD/PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant. Typically these individuals have doctoral or other professional degrees, although individuals at the masters or baccalaureate level may be considered senior/key personnel if their involvement meets this definition. Consultants and those with a postdoctoral role also may be considered senior/key personnel if they meet this definition. "Zero percent" effort or "as needed" is not an acceptable level of involvement for senior/key personnel.

Non-key Personnel: Personnel (such as research assistants) not contributing in a substantive, measurable way to the scientific development or execution of the project.

Other Significant Contributor (OSC): Individuals who have committed to contribute to the scientific development or execution of the project, but are not committing any specified measurable effort (in person months) to the project. These individuals are typically presented at “effort of zero person months” or “as needed” (individuals with measurable effort cannot be listed as Other Significant Contributors).

Consultant: An individual who provides professional advice or services for a fee, but normally not as an employee of the engaging party. Consultants also include firms that provide professional advice or services.

Now here is the tricky part, Consultants can be listed as Key, Non-key or Other Significant Contributors. Principal Investigators must carefully review the role of the consultant to decide which of the three categories a consultant falls into. If you have any questions on what role should be assigned, please contact Cindy Dickson or Sherie Donahue in Research Affairs.

Letters of support

Provide all appropriate letters of support, including any letters necessary to demonstrate the support of consortium participants and collaborators such as Senior/Key Personnel and Other Significant Contributors included in the grant application. Letters are not required for personnel (such as research assistants) not contributing in a substantive, measurable way to the scientific development or execution of the project.  Letters should stipulate expectations for co-authorship, and whether cell lines, samples or other resources promised in the letter are freely available to other investigators in the scientific community or will be provided to the particular investigators only. For consultants, letters should include rate/charge for consulting services and level of effort/number of hours per year anticipated.  In addition, letters ensuring access to core facilities and resources should stipulate whether access will be provided as a fee-for-service.  Do not place these letters in the Appendix. Consultant biographical sketches should be in the Biographical Sketch section.

Sherie Donahue, MS, CRA – Pre-Award Specialist Sr.
LOMA LINDA UNIVERSITY | Office of the Vice President for Research Affairs

Posted by Stan Jackson, OSP