Recovery Act: Update on ARRA Quarterly Reporting Requirements for Non-Competing Continuation Awards and Relinquished Projects; and Guidance to Avoid Common Errors

Notice Number: NOT-OD-10-065

Update: The following update relating to this announcement has been issued:

Key Dates
Release Date: March 19, 2010

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

Purpose

The purposes of this Guide Notice are to: 1) provide ARRA quarterly reporting guidance for NIH non-competing continuation awards; 2) provide guidance on reporting requirements for relinquished/transferred ARRA grants; and 3) help grantees avoid some common errors identified in previous reporting periods.

Background

The NIH has received funds from the American Recovery and Reinvestment Act of 2009 (“Recovery Act” or “ARRA”) to stimulate job creation and economic development activity related to medical and behavioral research for the Nation.  

To increase transparency for the public on how ARRA funds are used, NIH and its grantees are required to separately award, track, monitor, account for, report on, audit and close out ARRA funding. All awards funded by ARRA require quarterly reporting through www.FederalReporting.gov in accordance with Section 1512 of the Act.  This is in addition to the annual scientific progress reports submitted on the PHS 2590 and required financial reports submitted for most NIH grants.  More information on the ARRA quarterly reporting requirements, including the NIH Data Dictionary and NIH Readiness Tool, can be found on the NIH Recovery Act Recipient Reporting web page available at http://grants.nih.gov/recovery/recipient_reporting.html.

Policies

Clarification on Reporting Award Numbers and Award Amounts for ARRA Non-Competing Continuation (Type 5) Awards

Award Number:  Current OMB quarterly reporting guidelines include an Award Number data element defined as “The identifying number assigned by the Federal Agency, such as the Federal grant number, Federal contract number or the Federal loan number.”  This presents a problem for ARRA grants with multiple budget periods that receive a separate award following the review/acceptance of an annual progress report for the subsequent year.  For NIH awards the full grant number includes the award year; thus the grant number technically changes each year.  Although the grant number changes, separating these records in publicly-available reports as two unrelated grants may cause unnecessary confusion.  To avoid this confusion, when awards are incrementally funded, NIH requests that all grantees continue to use the grant number (and award date) of the original (e.g., Year 1) award even though the number has changed in the second year.  For instance, the initial NIH ARRA award grant number is 1R01GM654321-01.  While the 2nd year’s grant number technically becomes 5R01GM654321-02, for ARRA quarterly reporting purposes the grantee should continue to reference the grant number of the initial award; i.e., 1R01GM654321-01.  The NIH requirement for awardees to enter the full grant number with no spaces remains (e.g., 1R01GM654321-01).  This will allow awardees to continue to report this as a single continuous grant rather than as separate grants.

For ARRA-funded Administrative Supplements and Revisions awarded to ARRA-funded parent awards, a separate Notice of Award is issued with a unique Type 3 award number (e.g., 3 R01GM654321-01S1) reflecting cumulative information for the parent and the supplement.  The terms and conditions for these awards allow awardees to report on the entire ARRA funding separately or in a single quarterly report for both the ARRA parent and supplements/revisions. If your institution chooses to report these in a combined report, continue to use the award number of the original parent grant (e.g., 1R01GM654321-01) in the quarterly ARRA report.  This decision must be made in the first reporting period that includes an ARRA-funded supplement/revision and must be continued until the parent project is complete.  If already reporting separately you must continue separate reporting.

Amount of Award:  For the Amount of Award data element, NIH continues to request that grantees report all awarded direct (including consortium costs) and indirect/F&A costs for the project period awarded to date.  This includes any money awarded in the second (Type 5) year.  If any corrections are made by the awarding IC to increase or decrease the amount of award, the currently awarded total costs should be included, not the initial (incorrect) amount.

For ARRA-funded Administrative Supplements and Revisions awarded to ARRA-funded parent awards, the Notice of Award will reflect cumulative information for the parent and the supplement.  This will increase the total award amount, and the new total costs (including direct and indirect/F&A costs) should be submitted in the combined quarterly ARRA report.

Other Financial Data Fields:  Other financial data fields (such as Total Federal Amount of ARRA Expenditure and Total Federal Amount ARRA Funds Received/Invoices) should be reporting cumulatively and include funds awarded in all budget periods within the same project period.  This includes reports for ARRA-funded Administrative Supplements and Revisions awarded to ARRA-funded parent awards.

Guidance on Reporting Requirements for Relinquished ARRA Grants

NIH processes allow Recovery Act grants to be relinquished and to be transferred between institutions with prior NIH written approval.  However, this can cause data integrity problems and lead to submission of quarterly reports that unintentionally confuse the public.  To avoid those problems, NIH has set forth the following principles for quarterly reporting of relinquished and transferred grants.

If no dollars have been expended, then upon submission of a complete PHS 3734 Relinquishing Statement to NIH, the grantee’s reporting responsibilities cease.  However, at the time of the ARRA quarterly report, NIH systems may not have finalized the relinquishment yet; therefore, the grantee may be requested to explain why no report was submitted.

Since the original institution has expended ARRA funds, a report from the original institution will be expected until the date noted on the submitted PHS 3734 Relinquishing Statement has passed.  Reporting in subsequent quarters will then be the responsibility of the new institution once the Notice of Award (NoA) is issued documenting transfer of the grant.  The grantee relinquishing the grant should indicate “Final Report” in the appropriate quarter and include a note in the quarterly activity/project description field.

Common Grantee Submission Errors Identified in Previous Reporting Quarters

Grantee quarterly reporting submissions to NIH have been relatively free of significant errors and material omissions in the first two quarters.  However, to avoid future errors a few common errors have been identified that grantees should be aware.

Current OMB guidance defines “…jobs created or retained as those funded in the quarter by the Recovery Act.”  Unlike many other data elements, Number of Jobs is not a cumulative value and Recipients should not sum across multiple quarters of data as part of the formula for calculating jobs.  More on this definition can be found in OMB Memorandum M-10-08 available at (http://www.whitehouse.gov/omb/assets/memoranda_2010/m10-08.pdf).

NIH awardees must enter NIH code 7529 for Awarding Agency Code and Funding Agency Code.  Do not enter the code for the Department of Health and Human Services (7500) or any other value.

Enter the NIH Award Issue Date as reported on the initial Notice of Award.  If any modified NoAs are subsequently issued, the date on the initial NoA should continue to be used in the quarterly report; not the issue date of the modified award.   Note that when awards are incrementally funded, NIH requests that all grantees continue to use the award date of the initial (e.g., Year 1) award and not the award date of the Type 5 award. 

Enter 93.701 for all non-construction ARRA research grants, cooperative agreements, supplement, and revisions.  Use 93.702 for Construction (C06) and Repair, Renovation and Modernization (G20) grants only.

This is a unique value for each of the NIH Institutes and Centers.  Awardees can avoid errors in this field by referring to the TAS table provided on the NIH Recovery Act Recipient Reporting web site (http://grants.nih.gov/recovery/TAS_table.pdf) or by using information directly from the NIH Interim Readiness Tool (available at http://report.nih.gov/recovery/).

Inquiries

Questions concerning this Notice should be referred to NIHARRAReporting@mail.nih.gov.


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