Announcer: From the National Institutes of Health in Bethesda, Maryland this is All About Grants.
Megan Columbus: Welcome to another edition of All About Grants. This is Megan Columbus from NIH’s Office of Extramural Research. Here today to talk about close-out of grants. I have with me Michelle Bulls, the Deputy Director of OER’s Office for Policy of Extramural Research Administration. Could we start today by just explaining exactly what requirements are for the grantee for close-out?
Michelle Bulls: Absolutely. The grantees are required to submit the federal financial report, the final progress report and the final invention statement.
Megan: Okay. So let’s break that down a little bit so we can learn a little bit more about what we’re looking for, first with that financial statement.
Michelle: Okay, so for the federal financial report, the final report needs to include the final unobligated balances. There should be no unliquidated obligations, and the federal share and the federal outlays must match.
Megan: Okay, so I need a little bit of translation for this. What do you mean by unliquidated obligation? Could you give me an example of what that might be?
Michelle: There are times where they may have subcontracts. The subcontracts may not have been paid out, they may not have submitted their invoices to the prime grantee, and so the prime grantee cannot put that down as unobligated. It shows up as unliquidated because the invoice is out there, the money is slated to be obligated, but they have not paid it because they have not received the invoices back.
Megan: And what about that federal share versus federal outlay thing?
Michelle: The federal share is the amount that was authorized under the notice of grant award, and the outlays need to match that. If there is an outlay that doesn’t match the obligated balance, then the thought is there must be an unliquidated obligation because they haven’t outlaid that amount.
Megan: And so what happens if there is an unliquidated obligation?
Michelle: We cannot close out the grant.
Megan: Got it. Real briefly, because we’ll do another podcast that focuses more specifically on what’s required scientifically for the progress report. In general, what are we looking for in that final progress report?
Michelle: We’re looking for a list of accomplishments, whether they’re positive or negative. We want to make sure that we capture the fact that the grantee did expend the funds toward the goals and objectives of the project.
Megan: And at NIH, and I know I think this differs at other agencies, at NIH those final progress reports are not public documents. They’re not written for the public; they’re internal only. So that final progress report, what happens when someone’s planning on submitting a renewal application, which you may know as a type 2?
Michelle: Their final progress report is what they would put in the type 2.
Megan: So they wouldn’t need to submit it separately?
Michelle: They do not need to submit separately. Even if the grant is not funded, because they don’t make it through the peer review process, then the NIH would use that final report that’s in the type 2 to satisfy the requirement.
Megan: So if I’m submitting a renewal application, what about the FFR or the Final Invention Statement; are those required to be done at close-out?
Michelle: The grantee must submit a final FFR and a Final Invention Statement. And I want to add, whether or not there was an invention to report. If there’s not one to report they just need to say “none” and still report that invention statement.
Megan: So what happens if close-out isn’t completed as required?
Michelle: We really strongly encourage our grantees to close-out timely and that’s 90 days after the expiration of the project. If the grantee does not comply with that close-out requirement, just as with any other report, we would move into some enforcement actions. NIH really does not like to have to penalize the grantees, and so we strongly encourage them to maintain contact with their grant official. If they’re going to be delayed, we need to know that, so that we can work through those issues with them.
Megan: The reality is, from the NIH perspective, this is part of our ensuring stewardship and appropriate stewardship of federal funds, and making sure that we do our part.
Michelle: Absolutely. It’s definitely an accountability and stewardship issue.
Megan: And we’re a partnership, as in everything else NIH does with our grantee community.
Michelle: Absolutely. The other thing that I wanted to mention, too, is that we really strongly encourage the grantees to submit their final reports through the eRA Commons. And we ask that they use the eRA Common close-out module to do that. If they cannot do that they can actually PDF the final reports to the NIH Close-Out Center. And they can look in the NIH grants policy statement under the close-out chapter, section 8.6.
Megan: Thank you so much for joining us today. For NIH and OER, this is Megan Columbus.
Announcer: There is more information on award management at grants.nih.gov under the “About Grants” tab.