Reminder of Timeline for Administrative Changes to NIH Domestic Awards to Transition to Payment Management System Subaccounts

Notice Number: NOT-OD-15-105

Key Dates
Release Date: May 28, 2015

Related Announcements
NOT-OD-16-028
NOT-OD-14-103
NOT-OD-14-093
NOT-OD-13-120
NOT-OD-13-112
NOT-OD-13-111
NOT-OD-13-079
NOT-OD-12-139

Issued by
National Institutes of Health (NIH)

Purpose

This Notice is intended to remind and reiterate the implementation timeline, previously announced in NOT-OD-14-103, for the NIH transition to new U.S. Department of Health and Human Services (HHS) payment policies for domestic, non-competing continuation awards and use of Payment Management System (PMS) subaccounts.

Implementation Timeline Reminder
As of October 1, 2015, NIH will utilize only subaccounts for awarding grant funds. Every grant that is awarded funding in FY 2016 (whether it be in the first, second, third or fourth quarter of FY 2016) will be in a subaccount. The transition of all NIH awards to PMS subaccounts will be complete by September 30, 2016. Grantees with inadequate systems in place to appropriately manage this transition by October 1, 2015, may be unable to appropriately access PMS accounts and risk losing their ability to draw down funding. Grantees are advised that there will be no additional implementation delays considered and no exceptions granted to the deadline.

Applicable Policies for Non-Competing Continuation Awards
A Subaccount Transitional FFR for all intent and purpose is equated to an annual FFR. Applicable policies for non-competing continuation awards include:
Due Date for Subaccount Transitional FFR: the due date for Subaccount Transitional FFR expenditure reports is no later than 90 days after the end of the calendar quarter in which the budget period ended.

Unliquidated Obligations on the Subaccount Transitional FFR: If there are unliquidated obligations at the end of the first "administratively shortened" competitive segment, these may be reported on the subaccount transitional FFR expenditure data report.
Subaccount Transitional FFR for converted SNAP awards: If the award is under Streamlined Non-competing Award Process (SNAP), the grantee will be required to submit subaccount transitional FFR expenditure data that covers the project period from the original start date through the new project period end date.

Due Date for Progress Reports: There will be no change to the due dates, submission, or review of progress reports for domestic awards for FY 2016.

Recipients should use the SF-425 as they would for an annual FFR and mark annual in box 6. Additionally, grantees should enter Subaccount Transitional FFR in box 12.
Please see below for procedural changes in carryover of funds for non-competing continuation awards issued in FY 2016.

Carryover Funds and Federal Financial Reports for Domestic Non-Competing Continuation Awards during FY 2015 (October 1, 2015 September 30, 2016)

The requirement to submit the Subaccount Transitional FFR for non-competing continuation awards is to ensure that approved balances will be transferred to the PMS P subaccount and made available to the grantee. This requirement does not change the carryover authority listed in Section III of the NoA. If the award was issued with automatic carryover authority, OFM will automatically authorize the carryover in the PMS P subaccount equal to the amount of unobligated balance reported on the FFR. If the award was issued without carryover authority, OFM will automatically transfer the unobligated balance reported on the FFR to the PMS P subaccount; however, the grantee will still be required to submit a prior approval request to use carryover funds as detailed in the NIH Grants Policy Statement, Section 8.1.1.1. Failure to submit this Subaccount Transitional FFR will affect the availability of those and future funds.

Frequently Asked Questions
NIH has posted updated answers to frequently asked questions on the transition to PMS subaccounts on the following site: https://grants.nih.gov/grants/payment/faqs.htm based on this implementation timeline.

Inquiries

Please direct all inquiries to:

Division of Grants Policy
Office of Policy for Extramural Research Administration
Office of Extramural Research
Telephone: 301-435-0949
Email: GrantsPolicy@od.nih.gov