NIH GUIDE, Volume 22, Number 10, March 12, 1993

P.T. 34


  Grants Administration/Policy+ 

National Institutes of Health

Recipients of Public Health Service (PHS) nonconstruction grants are

required to submit the Financial Status Report (SF 269 or 269A) as

documentation of the financial status of grants according to the

official accounting records of the grantee organization.  Department

of Health and Human Services (HHS) regulations at 45 CFR Part

74.73(d) and Part 92.41(b) dictate that the FSR, when required on an

annual basis, must be submitted for each budget period no later than

90 days after the close of the budget period.  The late submission of

the FSR is a continuing problem for the PHS and the National

Institutes of Health (NIH).  While some grantees are in full

compliance with this requirement, many are not.  In fact, NIH data

show that 45 percent of the FSRs submitted during fiscal year 1992

arrived after the 90 day period.  Late submission of FSRs is not only

a violation of HHS regulations, but also may be an indication that

grantee accounting systems are deficient in meeting the federal

accounting standards required by the Office of Management and Budget.

The subsequent effort and follow-up on the part of the Division of

Financial Management (DFM) and the NIH awarding components to obtain

delinquent FSRs is time-consuming and labor-intensive for all

parties.  DFM regularly sends out a listing of past due financial

status reports to all grantee institutions, informing them of their

current status.  The latest report was mailed out in early January.

Staff at the NIH strongly believe that submission of timely FSRs is

critical.  Therefore, we want to work with you to identify the

reasons for poor performance in the past and the steps that can be

taken now to improve future performance.  The NIH is beginning

specific reviews of organizations that have been severely delinquent

or overdue in the submission of FSRs.  These institutions will be

requested to review their systems with a critical eye to recognize

the causes for late or delinquent FSRs, whether due to insufficient

staffing, inadequate computer systems, or problems with accounting or

organizational structure.  These institutions will have to develop

and submit a plan that identifies the problems experienced by the

institution that have prevented timely submission of FSRs in the

past; outlines the steps that will permit the institution to develop

the capability for submitting future FSRs on time, including a

timeline with milestones for improvement; and details the steps that

will be taken in order to submit currently delinquent reports.  If

performance is not improved, these institutions may be in jeopardy of

having sanctions imposed upon them until the problems are corrected.

It is extremely important that grant recipients submit financial

reports within the required time period.  Failure to comply with this

requirement may lead to delays or withholding of awards, loss of

automatic carryover authority, loss of advanced payments, loss of

expanded authorities, removal from participation in NIH-funded awards

under the Federal Demonstration Project, and designation as a high-

risk grantee.  Grantees should evaluate their record for submitting

FSRs as well as their current status.  If FSRs are being submitted

late, prompt corrective steps must be taken.  If necessary, outside

technical assistance should be obtained.  It is important to

reiterate that delinquency and lateness are serious concerns for all

institutions and administrative authorities may be withdrawn from any

institution that exhibits systemic problems or chronic lateness.

In an effort to assist the grantee community, the NIH has developed a

system for the Electronic Transmittal of Financial Status Reports, an

interactive computer-based communications system.  It enables the

electronic transmission of FSRs from the grantee organization to the

NIH mainframe computer.  The electronic process eliminates the manual

preparation, mailing, and handling of the hard-copy FSR, as well as

manual processing once it arrives at NIH.

There are several advantages derived from the use of this system:

FSRs transmitted via this system are processed within 72 hours; the

system gives users immediate feedback because it can detect errors;

electronically submitted FSRs cannot be lost in the mail or sent to

the wrong address; and users of the system can access current

listings of grants for which FSRs are past due or for which FSRs will

become due as of a specified period of time (terminating grants).


Additional information about the electronic system may be obtained by


Richard Rhoads or Priscilla Irick

NIH Division of Financial Management

Telephone:  (301) 496-5287


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