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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