A Busy Month at the National Institutes of Health

National Institutes of Health (NIH) policy staff were busy in August posting announcements including several that were noted in our Grants & Contracts blog:

Additionally, revised financial conflicts of interest requirements for NIH took effect as of August 24th, and an appeals court ruling upheld NIH’s funding of stem cell research.

A number of changes are coming for non-US NIH grantees and, because InfoEd Global has a number of non-US clients, this article focuses on those changes, which were announced in NOT-OD-12-139.

Foreign institutions receiving awards from NIH have historically received fixed quarterly advances on their awards. Beginning October 1, 2012, all new and continuing awards, payment will transition to the Payment Management System (PMS). PMS is the centralized cash management system of the Department of Health and Human Services.  All foreign institutions receiving NIH awards must register in PMS as soon as an FY 2013 award notice is issued. Awards to domestic institutions with foreign components are not affected by this change.

Foreign institutions also currently report expenditure data annually using the Federal Financial Report (FFR) via the eRA Commons. This too will be changing – for new SNAP awards issued after October 1, 2012, an FFR will only be required at the end of a competitive segment. Annual expenditure data will be monitored using data from PMS. This change does not affect existing awards or awards not issued under SNAP.

Similarly, for new awards issued after October 1, 2012, when preparing FFR expenditure data, grantees must use the currency exchange rate in effect at the time the funds are drawn down from PMS rather than the rate in effect at the time the FFR data are being prepared.

Finally, carryover of an unobligated balance from an award issued to a foreign institution prior to October 1, 2012 to an award issues after that date, will require that the grantee return the unobligated balance to the NIH at the time the FFR is submitted – regardless of whether the terms and conditions of the award provided for automatic carryover authority or prior approval was required. In the case that automatic carryover was stipulated, the Office of Financial Management will automatically authorize the carryover in PMS equal to the amount returned (consistent with existing policy regarding review of unobligated balances in excess of 25% of the authorized amount). Where an award was not issued with automatic carryover authority, a carryover request can be submitted with the FFR and returned unobligated balance and a revised Notice of Award will be issued if the request is approved.

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