NIH Announces New Closeout Feature in the eRA Commons and Reminds Grantees of Required Closeout Reports for NIH Assistance Awards

Notice Number: NOT-OD-05-051

Key Dates
Release Date: June 17, 2005

Issued by
National Institutes of Health (NIH) , (http://www.nih.gov)

This Guide Notice announces the availability of a new Closeout feature in the eRA Commons and reminds grantees of the importance of providing the Federal Government with timely and accurate final financial, progress, and invention reports as required by the terms and conditions of the assistance awards.

Closeout Feature in the eRA Commons

The eRA Commons now includes the capability to electronically submit required Closeout Reports—final progress report, final Financial Status Report (FSR), and final inventions statement. Commons-registered grantee institutions may now query in the Commons Status system for those grants that are in a closeout status. Commons users can then enter the Closeout screens to electronically process and submit the required reports. For the final progress report, users will attach a PDF, Word, or text file. For the Final Financial Status Report users are directed to the eRA Commons FSR system. For the Final Inventions Statement users indicate if any Inventions are being reported and when yes, are provided with text entry areas to report inventions. Note, a future enhancement of Closeout will include an automatic link to the IEdison system. Each required report can be submitted independently; however, grantees are reminded that closeout is not complete until all reports have been submitted.

Policy Reminder

NIH recipients shall submit within 90 calendar days after the last day of the final budget period a Final Financial Status Report, a Final Progress Report, and a Final Invention Statement and Certification (as applicable). It is important to note that unless the Grants Management Officer (GMO) of the respective awarding agency approves an extension of this 90-day reporting window in writing, grantees must submit the final reports within the prescribed timeframe.

1. The Final Financial Status Report (FSR) - (Standard Form 269 or 269A, whichever is applicable)

Grantees are instructed to submit a hardcopy or electronic final FSR directly to the Office of Financial Management (OFM), NIH. To expedite the process, electronically submitted FSRs through the NIH Commons are encouraged. The final FSR must indicate the exact balance of unobligated funds and may not reflect any unliquidated obligations. There must be no discrepancies between the final FSR and the Payment Management System's Federal Cash Transaction Report (SF-272). It is not acceptable to submit an inaccurate FSR in order to meet the reporting deadline and then submit a revised FSR to correct it. FSRs should be timely and accurate at the time of submission.

NIH's web-based FSR system allows participants to view currently due and late FSRs, as well as to submit FSRs electronically. Registrations to use this system are processed directly through the NIH Commons web site (http://commons.era.nih.gov/). To register or for questions on how to use the FSR module, please contact the eRA Commons Help Desk at:

NIH Commons User Support Branch
Help Desk (866)504-9552 (Toll Free)
(301)402-7469 (Voice)
(301)451-5675 (Fax)
(301)451-5939 (TTY)
commons@od.nih.gov

The FSR forms are available at: http://grants.nih.gov/grants/forms.htm. Hardcopy FSRs for NIH awards should be mailed to: Government Accounting Branch

Office of Financial Management
National Institutes of Health
31 Center Drive, Room B1B05A, MSC 2050
Bethesda, MD 20892-2050
(301) 402-9123 (Voice)

2. The Final Invention Statement & Certification (HHS 568)

The grantee must submit an HHS 568 form whether or not the funded project results in any subject inventions, and whether or not inventions were previously reported. The HHS 568 must list all inventions that were conceived or first actually reduced to practice during the course of work under the project, and it must be signed by the PI and an authorized institutional official. The completed form should cover the period from the original effective date of support through the date of expiration or termination or the award, and it should be submitted to the NIH awarding office.

To expedite the process, electronic submission through the eRA Commons is preferred; however, faxes or emails of a hard copy are also accepted. If there were no inventions, the form should indicate “None.” Copies of the HHS 568 form are available on the Edison website at https://s-edison.info.nih.gov/iEdison/ nihprocs.jsp or at http://grants.nih.gov/grants/forms.htm.

For certain mechanisms (C06, R13, R25, S15, Ts, and Fs), the Final Invention Statement is not currently required. In general, training, construction and educational mechanisms do not require invention reporting. For questions, the grantee should contact NIH awarding Institute or Center and follow their instructions.

When invention reporting is required, the HHS 568 does not relieve the responsible party of the obligation to assure that all inventions are promptly and fully reported directly to the National Institutes of Health, as required by terms of the grant or award. Additional information on invention reporting can be obtained from the office below.

Extramural Inventions and Technology Resources Branch
Office of Policy for Extramural Research Admin., OER, NIH
6705 Rockledge Drive, MSC 7980
Bethesda, MD 20892-7980
TEL: (301) 435-1986
E-mail: Edison@od.nih.gov

3. The Final Progress Report

A final progress report is required for any grant that has ended and any grant that will not be extended through award of a new competitive segment. This report should be prepared in accordance with instructions provided by the awarding component. At a minimum, it should include a statement of progress made toward the achievement of originally stated aims, a list of results (positive or negative) considered significant, and a list of publications resulting from the project, with plans, if any, for further publication. A copy of reprints or publications not previously submitted should accompany the final progress report. If publications have been submitted to the PubMed Central (PMC) archive, a reference to the PMC submission identification number may be included in lieu of submitting a hard copy. The final progress report also should address the following:

Report on the inclusion of gender and minority study subjects (using the gender and minority inclusion table as provided in the PHS 2590)

Where appropriate, indicate whether children were involved in the study or how the study was relevant for conditions affecting children (see “ Public Policy Requirements and Objectives—Requirements for Inclusiveness in Research Design—Inclusion of Children as Subjects in Clinical Research” (http://grants.nih.gov/grants/guide/notice-files/not98-024.html) and the PHS 398)

Describe any data, research materials (such as cell lines, DNA probes, animal models), protocols, software, or other information resulting from the research that is available to be shared with other investigators and how it may be accessed.

Commons-registered users may electronically submit this report through the new Commons Closeout feature. Alternatively, an original and one copy of this report can be submitted to the GMO. To expedite the process, faxes or emails are accepted.

If a competitive renewal (Type 2) has been submitted, whether funded or not, the progress report contained in that application may serve in lieu of a separate final progress report. In addition, at the discretion of the awarding unit, a reprint or preprint may be used for this purpose. Grantees should contact the assigned Grants Management Specialist for information on these alternatives.

Compliance Reminder

As NIH moves toward a systematic approach to identifying grantee institutions that consistently submit late closeout reports, it is important to understand the significance of noncompliance with these requirements.

Failure to submit timely and accurate final reports may adversely affect future funding to the organization and/or awards with the same principal investigator (PI). Accordingly, NIH may impose sanctions on institutions that fail to correct recurring reporting problems. Such sanctions may include restriction of facilities and administrative (F&A) costs, removal of authorities, delay or withholding of further awards to the project or program, removal from participation in NIH-funded awards under the Federal Demonstration Project, and/or designation as a high-risk grantee.

Late closeout may also extend the time period for retention of records by the grantee because the 3-year record retention period begins with the submission of the final FSR. See 45 CFR Part 74.53 and 45 CFR Part 92.42. Retention and access requirements for records.

The importance of submitting accurate and complete reports on time was also discussed in prior NIH Guide Notices “Closeout Reports Required for NIH Assistance Awards” (http://grants.nih.gov/grants/guide/notice-files/not99-136, 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.)

Inquiries

A more detailed discussion of reporting obligations can be found in the NIHGPS discussion on monitoring and reporting, located at http://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part8.htm#_Toc54600141.

Questions regarding Closeout policy may be directed to the Grants Management Specialist identified on the Notice of Grant Award.

Questions concerning specific records in the Commons Closeout system (e.g., missing records or records with incorrect dates) should also be directed to the Grants Management Specialist identified on the Notice of Grant Award.

General questions concerning using the eRA Commons should be directed to the eRA Commons Helpdesk at: commons@od.nih.gov.


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