NOT-OD-01-021: FINANCIAL STATUS REPORTS: REMINDER AND INFORMATION ON TIMELINESS AND ACCURACY REQUIREMENTS

Department of Health
and Human Services (HHS)
NIH... Turning Discovery Into Health^®

FINANCIAL STATUS REPORTS:  REMINDER AND INFORMATION ON TIMELINESS AND 
ACCURACY REQUIREMENTS

Release Date:  February 22, 2001

NOTICE:  NOT-OD-01-021

National Institutes of Health

PURPOSE

This Guide Notice is issued to remind grantees of Financial Status 
Report (FSR) requirements and to advise that NIH is renewing efforts to 
ensure recipient compliance with these requirements.

As discussed in the NIH Guide Notices  Closeout Reports Required for NIH 
Assistance Awards  
(http://grants.nih.gov/grants/guide/notice-files/not99-136.html, published 
8/10/1999),  Modified Financial Reporting Requirements  
(http://grants.nih.gov/grants/guide/notice-files/not96-178.html, published 
7/5/1996), and  Late Financial Status Reports  
(http://grants.nih.gov/grants/guide/notice-files/not93-082.html, published 
3/12/1993), grantees must provide the Federal Government all financial, 
performance, and other reports as required by the terms and conditions of the 
assistance awards.  NIH grantees are required by 45 CFR 74.71 to submit three 
closeout reports for every award:  Final FSR, Final Invention Report, and Final 
Progress Report.  Information on updated processing procedures for submitting 
FSRs will be issued in a future Guide notice.  Future guidance will also be 
issued to improve compliance with Invention and Progress report requirements.

POLICY

NIH recipients are reminded of the following requirements:

o FSRs (Standard Form 269 or 269A, whichever is applicable) must be submitted 
to NIH within 90 calendar days after the last day of each budget period unless 
the award is issued under the Streamlined Non-Competing Award Process (SNAP).  
For recipients under SNAP, FSRs are no longer required annually but, rather, are 
required 90 days after the end of the competitive segment.  (Reference NIH Guide 
Notice  Annual Financial Status Reports (SF 269) Required for Foreign and 
Federal Grantees,  
http://grants.nih.gov/grants/guide/notice-files/not99-058.html, published 
4/6/1999.)  For consortium partner arrangements, institutions must stipulate in 
agreements the deadlines for submitting reports to the prime.

Note:  Recipients that submit reports at the 3-month mark will be considered out 
of compliance if that period exceeds 90 calendar days.  Recipients are 
encouraged to report in advance of the deadline as a good business practice as 
well as to facilitate the timely submission of progress and invention reports.

o FSRs should be accurate at the time of submission, with revisions made 
rarely, only to provide updated information.  Revisions should not be used as a 
mechanism to correct routinely incomplete or erroneous FSRs.

Grantees are encouraged to submit FSRs electronically.  Information about the 
electronic transmittal of FSRs can be obtained by calling the NIH Office of 
Financial Management (OFM), Government Accounting Branch (GAB)   the receipt 
point for FSRs for NIH grants and cooperative agreements  -- at (301) 402-5297.  
OFM has established a web site,  Frequently Asked Questions Concerning Financial 
Status Reports (FSRs)  (http://www4.od.nih.gov/ofm/fsrfaq.pdf).

BACKGROUND

Following the streamlining of FSR requirements under SNAP, NIH is increasingly 
concerned about the prevalence of late reports and the excessive frequency of 
inaccurate and revised reports submitted by NIH grantees.  As part of its 
responsibility to provide oversight of the FSR process to ensure compliance with 
regulatory and policy mandates, NIH has worked to assist institutions in 
improving the submission of timely and accurate FSRs.  Past NIH efforts included 
a 1993-94 special initiative that identified persistent problems and established 
corrective actions.  Despite NIH efforts to make improvements, there continue to 
be problems with meeting reporting requirements.

PLANNED NIH OVERSIGHT EFFORT

To help improve grantee compliance with FSR requirements and to respond to 
outside audit recommendations for improved oversight, NIH is intensifying its 
efforts to monitor submission of FSRs.  NIH will continue reviewing data on FSRs 
to identify needed improvements and will follow up with individual institutions 
by requesting and monitoring institution corrective action plans, as needed.

Grantees should note that, as stated in the 8/10/99 Guide Notice on closeout 
reports, failure to submit timely and accurate final reports may affect future 
funding to the organization.  Accordingly, NIH will consider imposing sanctions 
to institutions that fail to correct recurring reporting problems.  Such 
sanctions may include restriction of facilities and administrative (F&A) costs, 
removal of expanded authorities, delay or withholding of further awards to the 
project or program, removal from participation in NIH-funded awards under the 
Federal Demonstration Project Expanded Authorities, and designation as a 
high-risk grantee.

ADDITIONAL INFORMATION

Reporting requirements are discussed further in the NIH Guide Notices  Closeout 
Reports Required for NIH Assistance Awards  
(http://grants.nih.gov/grants/guide/notice-files/not99-136.html, published 
8/10/1999),  Modified Financial Reporting Requirements  
(http://grants.nih.gov/grants/guide/notice-files/not96-178.html, published 
7/5/1996), and  Late Financial Status Reports  
(http://grants.nih.gov/grants/guide/notice-files/not93-082.html, published 
3/12/1993), and in the NIH Grants Policy Statement 
(http://grants.nih.gov/grants/policy/nihgps/), Part II, Terms and Conditions of 
NIH Grant Awards, Closeout section 
(http://grants.nih.gov/grants/policy/nihgps/part_ii_7.htm#closeout).

INQUIRIES

Questions regarding this policy may be directed to the staff listed at  Office 
of Financial Management Government Accounting Financial Status Report Processing 
Assignments,  http://www4.od.nih.gov/ofm/frs.htm.
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