STREAMLINING THE NIH NONCOMPETING AWARD PROCESS

NIH GUIDE, Volume 24, Number 38, October 27, 1995



P.T. 34



Keywords:

  Grants Administration/Policy+ 



National Institutes of Health



INTRODUCTION



On October 1, 1994, the National Institutes of Health (NIH)

implemented the Streamlined Noncompeting Award Process (SNAP).

Previous notices regarding SNAP appeared in the NIH Guide for Grants

and Contracts, Vol. 23, No. 38, October 28, 1994 and Vol. 24, No. 2,

January 20, 1995.  This notice provides information about the further

streamlining of SNAP, and supersedes information contained in

previous NIH GUIDE announcements.



In the spirit of the Federal government~s reinvention initiatives,

the NIH developed a streamlined process for the submission of

information necessary to receive a noncompeting award.  Before the

streamlining, a progress report and four financial documents were

required for each grant budget year.  This streamlining action

eliminated, where nonessential, two of those financial documents that

were part of the noncompeting continuation application kit (PHS

2590):  a budget for the next budget period and an estimated report

of expenditures for the current budget period.  The basic principle

of SNAP is that at the time of the competing award, the Grants

Management Officer negotiates the direct costs for the entire

competitive segment, thus eliminating the need to engage in annual

direct cost negotiations.  As part of that negotiation, NIH staff

assures that proposed costs are allowable, allocable, reasonable, and

necessary for the project.  Since the budget is negotiated for all

years of the competitive segment at the time of the initial competing

award, annual requirements for financial documentation are

streamlined in that only a programmatic progress report, the Federal

Cash Transactions Report, and the Financial Status Report are

required to enable NIH staff to monitor the scientific and financial

aspects of the project.



SNAP ELIGIBILITY



NIH grant recipients (including those participating in the Federal

Demonstration Project) are expected to follow the streamlined

noncompeting process for mechanisms routinely covered under expanded

authorities, except Program Project Grants (P01s) and Outstanding

Investigator Grants (R35s).  As published in the NIH Guide for Grants

and Contracts, Vol. 23, No. 45, December 23, 1994, NIH routinely

applies expanded authorities to Program Project grants (P01s),

Minority High School Student Research Apprentice Program awards

(S03s), Research Career Awards (K-Series), and all Research Project

grants (R-Series), except Phase I Small Business Innovation Research

(R43) and Small Business Technology Transfer (R41) awards.



Any award excluded from expanded authorities is routinely excluded

from SNAP, unless specifically included in SNAP as a term and

condition of the award.  Individual awards may be excluded from

routine inclusion under SNAP (and expanded authorities) based on the

following criteria:



o  Grants that require close project monitoring or technical

assistance, e.g., clinical trials, exceptional (high risk) grantees,

certain large individual or multi-project grants, or grants with

significant unobligated balances.



o  Grantees that have a consistent pattern of failure to adhere to

appropriate reporting or notification deadlines.



Any additional activity that has been included under expanded

authorities at the discretion of an awarding Institute or Center

(e.g., centers, training grants, or cooperative agreements), will be

excluded under SNAP, unless inclusion is specifically footnoted as a

term and condition of the award.



SNAP INSTRUCTIONS



The instructions for submitting the streamlined noncompeting

application require that the information below be provided at the

beginning of the Progress Report Summary (Form Page 5 from PHS 2590

kit, rev. 5/95).  These instructions are included in the PHS 2590

(rev. 5/95) under A. Simplified Instructions, page 2.  In providing

the information, the following guidance applies.



o  Has there been a change in the other support for key personnel?

Specific information is to be provided only if active support has

changed.  If a previously active grant has terminated and/or if a

previously pending grant is now active, the change in support is to

be reported.  Submission of other support information is not

necessary if support is pending or for changes in the level of effort

for active support reported previously.  Other support information

should be submitted only for the principal investigator and for those

individuals who are considered by the principal investigator to be

key to the project.  Key personnel is defined as an individual who

contributes in a substantive way to the scientific development or

execution of the project, whether or not a salary is requested.  Key

personnel is defined on page 11 of PHS 398 grant application kit

(rev. 5/95).



o  Will there be, in the next budget period, significant rebudgeting

of funds?  Significant rebudgeting occurs when expenditures in a

single direct cost budget category deviates (increases or decreases)

from the categorical commitment level established at the time of the

competing award by more than 25 percent of the total amount awarded

or $250,000, whichever is less.  The basis for determining

significant rebudgeting excludes the effects of carryover of prior

year unobligated balances, but includes competing or administrative

supplements.  This implementation redefines significant rebudgeting

contained in the current PHS Grants Policy Statement (rev. 4/1/94),

Pages 8-1 and 8-7.



o  Will there be, in the next budget period, a change in the level of

effort for key personnel?   A significant change in level of effort

is defined in Federal regulations as a 25 percent reduction in time

devoted to the project.  For example, if a key person on the project

is expected to reduce his/her effort from 40 percent to 30 percent,

which represents a 25 percent reduction in the level of effort, the

detailed budget page (Form Page 2) and the budget justification page

(Form Page 3) are to be submitted in the noncompeting continuation.

This requirement applies regardless of whether or not the key person

is compensated from the grant.



o  Explain any estimated unobligated balance (including prior year

carryover) that is greater than 25 percent of the current year~s

total budget or more than $250,000.  An estimated unobligated balance

that meets this criterion is to be reported on the Progress Report

Summary page (Form Page 5).  An explanation of why there is a

significant balance and how it will be spent if carried forward into

the next budget period is to be provided.



The questions regarding other support and significant rebudgeting

and/or change in level of effort must be answered by stating that no

change has occurred or is planned.  If a change has occurred or is

planned, the appropriate form and/or justification is to be submitted

in the noncompeting continuation application.  Information regarding

unobligated balances must be provided when it is anticipated that

there will be an unobligated balance (including prior year carryover)

of 25 percent of the current year~s total budget or more than

$250,000.



The Progress Report Summary (Form Page 5) is to be used to provide

the requested information, which should be provided before beginning

the progress report.  The progress report instructions contained in

pages 7-9 of the PHS 2590 (rev. 5/95) should be followed for

reporting on research progress.  Separate progress reports are

routinely required for special supplements awarded specifically to

support the addition of an individual to the project.  The Research

Supplement for Underrepresented Minorities and the Research

Supplement to Promote the Recruitment of Individuals with

Disabilities into Biomedical Research Careers are examples of special

supplements requiring separate progress reports.  A separate budget

for these special supplements is not required unless there is a

significant change as discussed above.



SNAP PHASE II



The second phase of SNAP is a logical extension of the award process

and involves the Noncompeting Notice of Grant Award.



Beginning October 1, 1995, noncompeting award notices for grants

subject to the SNAP will be issued without direct cost categorical

breakdowns (e.g., personnel, supplies).  Award notices will provide

only the total direct and indirect costs awarded for that budget

period.  For this phase-in year, indirect cost base and rate

information will be provided either on the award notice or as an

attachment.  Although SNAP awards provide no categorical breakdown of

direct costs, recipients are required to allocate and account for

these costs by category in accordance with applicable cost

principles.



Future Year Commitments:  Remaining future year commitments will be

modified to reflect total cost (both direct and indirect)

commitments.  (See NIH Guide notice "Future Year Commitments on NIH

Grant Awards" in this issue.)



PRIOR APPROVAL REQUIREMENTS



The grant mechanisms included in SNAP are administered under the

Expanded Authorities' provisions of OMB Circular A-110, which waives

cost related prior approvals.  The prior approval authorities

retained by PHS will remain in effect under SNAP.  However, three

indicators of "Change of Scope or Research Objectives" as contained

in the PHS Grants Policy Statement on page 8-7 (rev. 4/1/94), require

clarification since noncompeting awards under SNAP will not have

categorical direct cost breakdowns.



a.  Initiating patient care activities where none had been approved

during the negotiation of a competing award will continue to signify

a change in scope and is based on programmatic changes rather than

rebudgeting actions.



b.  Initiating a subcontract that transfers a substantial portion of

the work to a third party where none had been approved during

negotiation of competing award also remains an indicator of a change

in scope and is based on programmatic changes rather than rebudgeting

actions.



c.  Significant rebudgeting continues to be an indicator of change of

scope.  However the basis on which significant rebudgeting is

determined has been redefined.  (See above.)



INQUIRIES



Grantee staff with questions about SNAP should contact the Grants

Management Specialist identified on the Notice of Grant Award.



.

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