Frequently Asked Questions

When must ARRA projects be completed?
All ARRA funds must be obligated by NIH no later than September 30, 2010. In general this will mean ARRA project period end dates will be no later than September 29, 2011. However, all ARRA awards are subject to the standard terms of award as indicated in the NIH Grants Policy Statement, including the authority to extend the final budget period of a previously approved project period for up to 12 months without additional funds.
Are no-cost extensions permissible for Challenge Grants?
The proposed award period in the Challenge Grant application will end on or before 9/29/2011. There are no specific constraints on no-cost extensions for the Challenge award program. All ARRA awards are subject to the standard terms of award as indicated in the NIH Grants Policy Statement including the authority to extend the final budget period of a previously approved project period for up to 12 months without additional funds. See https://grants.nih.gov/grants/policy/nihgps_2003/index.htm

B. Recovery Act Terms of Award

Are there special reporting requirements for NIH's ARRA programs?
Yes. In addition to the NIH General Terms of Award (https://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_part4.htm), there are special reporting requirements for recipients of ARRA funds (https://grants.nih.gov/grants/policy/NIH_HHS_ARRA_Award_Terms.pdf) (PDF - 40 KB). The ARRA reporting requirements must be met on a quarterly basis and submitted through www.FederalReporting.gov. Details on these quarterly reporting requirements are available from the NIH Recovery Act Recipient Reporting web site available at https://grants.nih.gov/recovery/recipient_reporting.html.
Do the Standard ARRA Terms and Conditions for Division A Funds, dated March 2, 2009, or subsequent versions, apply (i.e., flow-down) to subrecipients?
Grantees must impose the ARRA Terms and Conditions upon subrecipients, and must separately identify for each subrecipient, and document at the time of subaward and at the time of disbursement of funds, the Federal award number, any special CFDA number assigned for ARRA purposes, and amount of ARRA funds. In order for the grantee to meet its quarterly reporting obligation to the federal government, it must require subrecipients to account for, track, and report to the grantee on ARRA funding in such a way that distinguishes the funding from non-ARRA funds. For purposes of reporting to the federal government, the recipient must submit detailed information on sub-awards to include the data elements required required to compy with the Federal Funding Accountability and Transparency Act of 2006 (Public Law 109-282). Those requirements are that for any subaward equal to or larger than 25K, the following information must be reported:
- The name of the entity receiving the sub-award;
- The amount of the sub-award;
- The transaction type;
- The North American Industry Classification System code or Catalog of Federal Domestic Assistance (CFDA) number;
- Program source;
- An award title descriptive of the purpose of each funding action;
- The location of the entity receiving the award;
- The primary location of performance under the award, including the city, State, congressional district, and country; and
- A unique identifier of the entity receiving the award and of the parent entity of the recipient, should the entity be owned by another entity.
Subawards less than 25K or to individuals may be reported in the aggregate. The definition of terms and data elements and specific instructions for reporting including required formats, will be provided in subsequent guidance issued by HHS.
Can an ARRA-funded grant be transferred to a new institution if the PI moves?
NIH Policy supports such a transfer. Although the requirement by the HHS Payment Management System to have a unique Document Number schema for ARRA awards caused some problems with transfers during the initial ARRA period, as of October, 2009 processes have been put in place to accommodate these requests and there should not be any problems. But please note the following documentation requirements for transfers of ARRA-funded awards.
- If the transfer request is for a project that has received only Recovery Act funding (including ARRA administrative supplements or competitive revisions to ARRA-funded parent awards), then the standard NIH paperwork requirements will apply.
- If the transfer request involves an ARRA-funded administrative supplement or competitive revision (Type 3) to a non-ARRA funding parent award, the requirement to treat ARRA funds separately from non-ARRA funds means that institutions involved in the transfer will need to submit 2 relinquishing statements, 2 invention statements, a Type 7 applications and eventually 2 separate FSRs. If more than one ARRA Type 3 was issued, all the ARRA funding can be reflected in the same ARRA-specific document.
Additionally, please note the NIH ARRA quarterly reporting guidance for transfers of ARRA-funded grants at NOT-OD-10-065.
What are the reporting requirements for the Federal Cash Transactions Report (SF 272) when grantees have both non-ARRA & ARRA awarded funds?
Since ARRA funds are posted in a "P" account and non-ARRA funds are posted in a "G" account, separate Federal Cash Transactions Reports (SF 272) will be required for both (P and G); a single consolidated 272 for ARRA & non-ARRA funds is not an option. Grantees may access the SF 272 report at the PIN level using the same password as before. Once logged into the Division of Payment Management (DPM) Electronic 272 System, grantees may access all of the Payment Management System (PMS) Payee Accounts assigned to that PIN, and are required to complete a separate SF 272 report for each PMS Payee Account. Grantees may direct additional questions to the PMS Account Representative found on previous SF 272 reports. New grantees may direct questions to the PMS Help Desk via phone (877) 614-5533 or E-Mail [email protected].
An ARRA-funded supplement has been made to a parent grant that is funded with non-ARRA funds. Are separate Federal Cash Transactions Reports (SF 272s) required for the parent and the ARRA-funded supplement?
Yes.
An ARRA-funded supplement has been made to a parent grant that is funded with non-ARRA funds. The ARRA supplement will end several years before the parent. Do we need to separately closeout the ARRA-supplement at the time it ends?
Yes. As noted in the ARRA-specific term for all ARRA supplements and competing revisions, separate closeout documents (Final Progress Report, Final Financial Status Report and Final Inventions Statement) will be required to close out the ARRA funding even when the parent grant continues.

C. Future Submission Options

What are the future submission options for an ARRA application that was reviewed but will not be funded?
After the initial peer review process has been completed and summary statements are available in eRA Commons, applications that were submitted to RFAs and are not selected for funding may be submitted in response to another funding opportunity announcement (FOA). These applications must be submitted as new applications, not resubmissions. Therefore, the application should not include an introduction, should not make references to the previous review, and should be submitted for the appropriate due date for new applications as noted in the FOA. More information on this policy can be found in Guide Notice OD-09-100.

Revision applications received in response to Notice OD-09-058 were not submitted to an RFA and, if submitted again, must be submitted as a resubmission of the revision with an introduction that responds to the previous review.
If an ARRA application was determined to be not responsive/not compliant and was not reviewed, what are the future submission options?
Since the application was not peer-reviewed, it can be submitted as a new application to another applicable funding opportunity announcement (FOA) without delay. Please make sure to follow all application instructions, as well as special instructions in the FOA to which you are applying.
If an applicant accepts a two-year ARRA award that covers general progress on all the original aims, what are the future submission options in two years?
A renewal application should be submitted in this case. A brief cover letter should be included, explaining why progress on the aims may be less than expected.
If an applicant accepts a two-year ARRA award that covers only a portion of the original aims, can a new application be submitted for the withdrawn aims now?
Yes. If the award or other official communication from NIH specifically reduced the aims and budget and was documented in the Notice of Grant Award, other official correspondence, or as a changed abstract, an applicant can submit the withdrawn aims in a new application. A brief cover letter should be included, explaining why some of the aims may appear to overlap with a previous application. If the change of scope was documented in a separate e-mail or letter (and not in the Notice of Award), that document should be included as part of the cover letter.

II. NIH Challenge Grants

A. Reporting Requirements

How will the funds awarded from NIH's ARRA program be tracked?
New and distinct Catalog of Federal Domestic Assistance (CFDA) numbers have been created to correspond with and track all awards issued under ARRA. The public can track all ARRA funds through the central Recovery.gov Web site.

III. ARRA Administrative Supplement and Competitive Revision FAQs

A. General Questions

Are there special Closeout requirements for NIH's ARRA programs?
With the minor exception of those cases described below, NIH grantees with ARRA-funded administrative supplements and revisions are required to submit separate closeout documents (Final Progress Report, Final Financial Status Report, and Final Invention Statement) to closeout the Recovery Act funding at the time the ARRA funding ends. These closeout reports for the ARRA funding are required even when the parent grant continues beyond the period of ARRA support. The only two exceptions are:
- In situations where multiple ARRA supplements and/or competitive revisions are awarded to the same parent grant, awardees are only required to submit a single Financial Status Report (FSR) at the time the project period of the last ARRA supplement or revision ends (e.g., after the project periods for all other supplements and revisions have also expired). Reminder, when multiple ARRA supplements/revisions are awarded, if any one of the awards is extended, then the FSR due date for all the ARRA supplements/revisions is also extended.
- In situations where an ARRA supplement/revision is awarded after a previous ARRA supplement/revision has already been terminated and closed out, a revised SF269 Financial Status Report will need to be submitted at the end of the last awarded ARRA supplement/revision.
In cases where the parent and supplements/revisions are all awarded with ARRA funds, standard closeout procedures apply; e.g., only a single FSR is required at then end of the ARRA project period. In cases where a supplement has ended, but remains open pending the completion of another supplement, information on any additional supplement activities should be submitted in the progress report of the parent grant, as described above.
More on this subject can be found in NOT-OD-10-066.

IV. Recovery Act Section 1512 Recipient Reporting

A. General Questions

To whom do the reporting requirements apply?
All ARRA-funded, NIH extramural grant or cooperative agreement recipients must report information in accordance with Section 1512 of the Recovery Act on a quarterly basis using the www.FederalReporting.gov Web site. According to Section 1512 of the Recovery Act, prime recipients are responsible for fulfilling the reporting requirements for both prime and sub-recipients. Although prime recipients may delegate the reporting responsibilities to sub-recipients, the reporting requirement is a requirement of the recipient and final responsibility for the accuracy and timeliness of the data remains with the prime grantee. In case of NIH-awarded grants or cooperative agreements, the prime recipient is the grantee institution. In cases where the prime recipient enters into a legal consortium or subcontract arrangement with another institution whereby the reporting terms would flow down to that other institution, that institution would be considered a sub-recipient. See the appendix of the OMB Guidance for definitions of recipients and sub-recipients.
What is the role of the PI in reporting?
This may vary depending on the procedures established by the grantee institution. The institution is considered the grantee and is responsible for determining processes within the institution for completing the reporting requirements. The PI may or may not be involved.
How long does the recipient have to enter data?
The reporting window lasts from the 1st to the 10th of each reporting month. In addition, the 11th � 21st day of each reporting month is available for recipients to review the data submitted and make any necessary corrections. On day 22 of the reporting month, all data submitted will be "locked" and cannot be modified unless "unlocked" by the Federal awarding agency.
What are the ramifications of non-compliance with the recipient reporting requirements?
Non-compliance of this reporting requirement will be treated as failure to comply with the terms and conditions of award and will be subject to the enforcement actions outlined in the Enforcement Actions section of the NIH Grants Policy Statement.
The OMB 6/22/2009 guidance document defines a recipient and sub-recipient as "non-Federal entities." We have a consortium arrangement with a National Laboratory. Are they ineligible to receive ARRA funding?
In most cases the National Laboratory is a FFRDC (Federally-Funded Research Development Center) or GOCO (Government Owned/Contract Operated) facility. In these cases the prime recipient or sub-recipient is actually a contractor that is a non-profit University, industrial firm, or other non-profit organization. PIs and key personnel are employed by the contract organization, rather than the Federal agency. Since the grantee is actually the contractor (a non-Federal organization), OMB has indicated there is no concern with these organizations receiving ARRA funding as either a prime or sub-recipient.
It would appear that most of the data being requested is already being reported by Federal agencies under the requirements of the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Why do recipients have to provide data that is already available from Federal agencies?
NIH and HHS have developed a Readiness Tool that will provide as much of the data as possible from the NIH eRA database and the HHS TAGGs database. This tool can be accessed at http://taggs.hhs.gov/ReadinessTool/. You can also find much of this data on the NIH Report Recovery Act Web site.
Who can I contact for additional assistance?
Contact the FederalReporting.gov helpdesk to obtain assistance with user functions related to the registration and reporting processes.
If recipients have a question that cannot be answered by the FederalReporting.gov helpdesk whom should they contact at NIH?
The NIH Grants Information help desk will be handling calls and inquiries on ARRA recipient reporting. Grantees should not routinely contact their assigned grants management specialist or program official on issues concerning this quarterly reporting requirement.
Where can I find recordings of the OMB Webinars conducted July 20-July 23, 2009?
Recordings of the Webinars are available at: https://www.federalreporting.gov/federalreporting/downloads.do.
How will the reports entered into FederalReporting.gov be made available to the public?
On the 30th day of each reporting month, all reports will be made available on www.Recovery.gov and on individual Federal agency recovery Web sites.
My institution received an ARRA award from NIH, but then the PI moved so the entire award was cancelled. Must we still comply with the Section 1512 report?
No. If the award was relinquished before any funds were expended there is no requirement to report on the project. However, if the grant is relinquished and transferred after funds have already been expended, the original institution must submit a report on the funds expended in the quarter the grant was relinquished. This report should state "Yes" in the final report field, indicate "Fully Completed" in the project status field, and briefly note the transfer in the project status field.
Do ARRA reporting requirements replace standard NIH reporting requirements?
No. ARRA quarterly reports fulfill the requirements of section 1512 of the Recovery Act. These reports are submitted to FederalReporting.gov and are in addition to NIH-specific scientific progress and financial reports. For a description of NIH-specific reporting requirements, please see the NIH Grants Policy Statement: https://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part8.htm#_Toc54600141.
Who is the point of contact for NIH, the prime recipient or sub-recipient(s)?
NIH's communication will be with only the prime recipient, even if the prime recipient has delegated the reporting requirement to sub-recipients.
What happens if the reporting deadline date falls on a weekend or Federal holiday?
The recipient data entry period lasts from the 1st to the 10th calendar day of the reporting month. It is the responsibility of recipients to enter their reports during this period. NIH does not have authority to change this deadline but recommends that grantees monitor the FederalReporting.gov web site for any changes authorized by OMB.
Can states report on behalf of state colleges and universities?
NIH considers the college or university the recipient, not the state. Although States may perform the date entry on behalf of a college or university, the reporting requirement is a requirement of the recipient; therefore, NIH expects the college or university to manage this requirement and final responsibility for the accuracy and timeliness of the data remains with the prime grantee. In addition, should any follow-up or clarification be needed for a particular report, NIH would contact the college or university.
Can a parent university report on behalf of its associated colleges/schools?
Prime recipients of NIH grant awards are responsible for providing quarterly reports through FederalReporting.gov, and they are solely accountable to NIH for the accuracy, timeliness and completeness of those reports. If NIH recognizes the college/school as a separate grantee institution from the parent university, we consider the college/school the prime recipient. For instance, if a medical school is recognized as a separate applicant organization from its parent university, then we would expect the medical school to report. If any follow-up or clarification is needed for a particular report, NIH will contact the Authorized Organizational Representative of the recipient we recognize as the grantee.
Are prime recipients receiving an award under $25,000 required to submit a quarterly recipient report for the project to FederalReporting.gov?
No. OMB addressed this question in an FAQ clarifying their June 22 guidance, "Prime recipients of Recovery Act funds for awards below the $25,000 threshold are not required to submit recipient reports; however, prime recipients issuing sub-awards are required to report these in aggregate." Although NIH grants under $25,000 will be listed in the HHS Recipient Readiness Tool and the NIH Interim Readiness Tool, NIH does not expect grantees to submit reports for these grants. More information is available at http://www.whitehouse.gov/omb/recovery_faqs/#agg1.

B. Registration

My institution is already registered in CCR and Grants.gov. Do we need to separately register in FederalReporting.gov?
Yes, separate registration in FederalReporting.gov is required.
How do recipients register to use FederalReporting.gov?
Recipients should register with www.FederalReporting.gov soon after receiving their award. You only need to register once. To register, prime and sub-recipients must have a Dun & Bradstreet (DUNS) number, and prime recipients must be registered in the Central Contractor Registration (CCR) database. Recipients who do not already meet these requirements should take immediate steps to prepare for registration. Further detailed information on CCR and D&B is available at http://www.ccr.gov/FAQ.aspx and http://fedgov.dnb.com/webform.
Who should I contact with registration questions?
The registration and reporting processes are supported by the FederalReporting.gov helpdesk.

C. Data Entry

How does a recipient submit reports into www.FederalReporting.gov?
There are three methods available to submit reports into FederalReporting.gov. The reporting organization can choose the most convenient method for reporting among the following:
- Online data entry in a Web browser: The FederalReporting.gov Web site will provide a straightforward data entry form, available via the user's Web browser, for report data entry.
- Excel spreadsheet: A Microsoft Excel spreadsheet template is available for report submission. The user can download this spreadsheet at https://www.federalreporting.gov/federalreporting/downloads.do, open the spreadsheet in Microsoft's Excel spreadsheet program and fill it in.
- Custom software system extract in XML: Organizations with sufficient technical experience may choose to submit a properly formatted Extensible Markup Language (XML) file for their report submission. The XML schema can be downloaded at https://www.federalreporting.gov/federalreporting/downloads.do.
How long does the recipient have to enter data?
The reporting window lasts from the 1st to the 10th of each reporting month. In addition, the 11th � 21st day of each reporting month is available for recipients to review the data submitted and make any necessary corrections. On day 22 of the reporting month, all data submitted will be "locked" and cannot be modified unless "unlocked" by the Federal awarding agency.
In Section 2.3 of the OMB guidance (page 10) there is a sentence indicating "Administrative costs are excluded from the reporting requirements." Does this mean the administrative portion of F&A/indirect costs should not be reported?
No. Grantees are required to report on the total costs awarded, which include both direct and F&A/indirect costs. OMB will issue a clarification on what is meant by "administrative costs" in this context. However, it does not mean the administrative portion of F&A.
How does a recipient make a report correction to a submission?
A recipient may decide, or may be asked by a subsequent reviewer, to make a correction to a submission. The entity submitting the report is the data owner of the submission and is therefore responsible for applying any corrections. If the data was submitted in an online form, the data fields can be modified and saved. If submitted via Excel spreadsheet file or XML upload, a new file with corrections will need to be uploaded. Recipients will have until the 21st of each reporting month to make corrections. After that date, the data will be locked and cannot be modified by the recipient unless the Federal agency unlocks the data or until the continuous Quality Assurance (QA) period begins.

After the 30 day submission and review period, all recipient reports will be unlocked and available for recipients to correct their reports. If instructed by NIH to fix a material omission or significant error, awardees should use the existing FederalReporting.gov processes to submit revised reports. These will be reviewed by NIH using the same criteria applied to all other quarterly report submissions.

For reports that do not have significant errors or material omissions, recipients should use the next quarterly report to make the correction.
What is a TAS and where can a grantee find this for a particular award?
TAS stands for Treasury Account Symbol; a unique number for each Institute/Center (IC). A TAS number look-up tool is provided on the Excel spreadsheet reporting template. Tip: All NIH IC TAS numbers begin with 75. The TAS should be entered as follows: 75-XXXX. For example, an award from the National Cancer Institute would be entered as 75-0850. Note: Not all the codes in the look-up tool that begin with 75 are for NIH awarding components. Recipients should only use the code associated with the IC assigned to a particular award.

We expect recipients directly entering data into FederalReporting.gov will have a similar tool or a drop-down list of values from which to choose the appropriate TAS number. A table of TAS numbers for each IC is also available at https://grants.nih.gov/recovery/recipient_reporting.html.
If a grant is for construction, should the recipient use TAS number 75-0589 Building and Facilities?
No. For constructions grant awards, recipients should use 75-0847 for the National Center for Research Resources.
What is the Sub Account Number for Program Source (TAS)?
The Sub Account Number for Program Source (TAS) is 009 for all NIH awards. Note: This number is not related to the fiscal year of the award; it will always be 009. However, according to the OMB data dictionary (v3.0) and Excel spreadsheet template, this is an optional data field, and NIH has no plans to verify it.
Our institution received an ARRA-funded C06 Construction grant. Is this considered an "infrastructure investment" for the purposes of ARRA recipient reporting?
In general, no. The requirement for infrastructure reporting only applies to grantees that are units of state or local government. Therefore, NIH C06 grantees that are an institution of higher education, a non-profit organization, or any other type of non-governmental organization using the uniform administrative requirements of OMB Circular A-110 (45 CFR Pt 74) are not required to report on infrastructure investments.
Are scientific progress reports required as part of the ARRA recipient reporting?
No, ARRA quarterly reports are not to be considered scientific progress reports. For the "Quarterly Activities/Project Description" data element, NIH is advising grantees if there are no significant changes from the "Award Description" field to enter, "As defined in the Award Description field." Otherwise only include significant changes.
Where can I find the information and NIH guidance that I need in order to complete my report accurately?
HHS has provided a Readiness tool that provides as much of the data as possible from the NIH eRA database and the HHS TAGGs database. This tool can be accessed at http://taggs.hhs.gov/ReadinessTool/. Remember if you are reporting on a supplement, do not use the parent abstract. Please write a brief description of the purpose of the supplement. Additional NIH-specific guidance on many of the data elements is available in the NIH Data Dictionary (Excel - 114 KB).
Our awards are not correctly showing up in The HHS Readiness Tool list. Some appear to be missing, some list an incorrect DUNS number for our institution, and some list an award date inconsistent with the NIH Notice of Award. What should be reported in the quarterly report and will this affect report submission?
In some cases the HHS Readiness Tool is listing incorrect DUNS numbers or award issue dates, and in a few cases this means the awards are not correctly associated with your organization. Please enter the correct information in your quarterly report based on the most current information you have available at this time. These inconsistencies should not affect report submission to FederalReporting.gov. During the agency review period, NIH will be using the data in our own systems to perform data quality checks, not the HHS Readiness Tool data. If you would like to verify your data with our system data please refer to the NIH Readiness Tool (Excel - 10 MB).
What should I do if I do not have the DUNS Number for my vendor?
Per the OMB June 22, 2009 guidance, the DUNS number is preferred for prime recipient and sub-recipient vendors. If the DUNS number is not available, the report must include the vendor name and the zip code associated with vendor's headquarters.
What types of federal financial assistance fall within the Award Type category "grants" for the purpose of ARRA reporting?
All NIH ARRA grants and cooperative agreements, including training grants, career development awards, individual fellowships and all administrative supplements and competitive revisions should be designated as "grants" in the "Award Type" field.
Is the Activity Code requested in ARRA reporting requirements the same as the NIH activity code that is part of the NIH grant number?
No, this is a separate code provided by North American Industry Classification System (NAICS) or the National Center for Charitable Statistics (NCCS). The majority of NIH grantees should choose an appropriate NTEE or NPC code. NAICS codes are used only by recipients of construction grants that are awarded to a state or local government.

A drop-down list of all NAICS, NTEE, and NPC codes is available on the right side of the Excel template. Note: NTEE codes were absent from earlier versions of the templates. They were added to the latest version (1.3). You can also search for NPC codes at http://nccsdataweb.urban.org/PubApps/nteeSearch.php?codeType=NPC or browse a two-page list of NTEE codes at http://nccsdataweb.urban.org/kbfiles/324/NTEE%20Two%20Page_2005.DOC .

NIH anticipates that most ARRA grantees will choose an NPC and/or NTEE code(s) within the Major Category title Health, subcategory H - Medical Research. The NPC code **K - Research and Public Policy Analysis might also be appropriate.

Acceptable entries for an NIH ARRA grant focused on breast cancer research might be one or more of the following NPC codes: H01 (Medical Research General/Other), H02 (Diseases and Disorders Research), H02.04 (Cancer Research), H02.04.03 (Women's Cancer Research), or **K (Research & Public Policy Analysis). Acceptable NTEE codes might include: H- NTEE (Medical Research), H30 - NTEE (Cancer Research), or H32 - NTEE (Breast Cancer Research).
Does the Total Federal Amount of ARRA Expenditure need to equal the Total Federal Amount ARRA Funds Received/Invoiced?
Not necessarily. The Total Federal Amount of ARRA Expenditures should equal the value of expenditures within the grantee's accounting system. Grantees should report figures to the best of their knowledge and ability at the time each report is due.
What is the CFDA number? What should I enter here?
CFDA number refers to an agency's entry in the Catalog of Federal Domestic Assistance, a published description of Federal assistance programs. All recipients of NIH non-construction ARRA research grants, cooperative agreements and supplements should enter 93.701 in this section. Recipients of Repair, Renovation and Modernization (G20) grants should also use CFDA 93.701 though previous FAQ responses mistakenly requested use of 93.702. Only recipients of NIH ARRA Construction (C06) grants should enter 93.702.
Our institution entered data into version 1.5 of the Excel data template before the successive versions became available. Will these reports upload to FederalReporting.gov on April 1st?
NIH recommends using the validation tool available at FederalReporting.gov. If your report passes validation, there is a good chance it will be accepted by the system. However, recipients should prepare for the possibility that they will have to cut and paste their entries into the latest Excel version prior to uploading their reports.
In Section 2.3 of the OMB guidance (page 10) there is a sentence indicating, "Administrative costs are excluded from the reporting requirements." Does this mean the administrative portion of F&A/indirect costs should not be reported?
No. Grantees are required to report on the total costs awarded, which include both direct and F&A/indirect costs.
If a recipient makes multiple payments to a single vendor that adds up to more than $25,000 is additional reporting required?
Vendor reporting information is triggered by a single payment of greater than $25,000 by the prime recipient or sub-recipient. If the vendor receives multiple payments that each individually are less than $25,000 (but in total are greater than $25,000) in a quarter, the vendor reporting requirements are not triggered. However, aggregate reporting of these payments still is required in the "Total Amount of payments to vendors less than $25,000/award" and "Total Number of payments to vendors less than $25,000/award" fields.

In addition, please note that in a series of FAQs from OMB they clarify that the $25,000 threshold is triggered by individual payments to a vendor within a quarter and not cumulative payments to a vendor over the life of the project.
What Agency Code should be entered for NIH awarded grants?
Enter NIH's agency code (7529) into the Funding Agency Code and Awarding Agency Code fields of the report. Do not enter the code for the Department of Health and Human Services (7500). Entering the incorrect code makes it difficult for NIH to properly review the grant and may cause NIH to incorrectly consider the report missing.
If a subaward is planned but not yet executed/signed, does it need to be reported on the quarterly report?
No, the subaward does not need to be reported until the quarterly report following its execution.
I received an ARRA award in 2009 with a future year commitment and received the Type 5 (non-competing continuation) award in 2010. Should I report these as separate grants in FederalReporting.gov, or combine the data in some way?
To best present data on this award to the public that reflects the continuous nature of the award, NIH requests that awardees continue to use the award number and award date of the original (i.e., Year 1) award when grants are incrementally funded. 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). More on this can be found in NIH Guide Notice NOT-OD-10-065 available at https://grants.nih.gov/grants/guide/notice-files/NOT-OD-10-065.html.

In addition, information for the "Project Status," "Award Amount," "Total Federal Amount of ARRA Funds Received/Invoiced," "Total Federal Amount of ARRA Expenditure" and other cumulative financial data fields should reflect the entire Recovery Act project period to date, and the "Award Date" field should reflect the award date of the original (e.g., Year 1) award and not the Type 5 award. This will allow awardees to continue to report this as a single continuous award rather than as separate awards.
What information is required in the “Quarterly Activities/Project Description” field?
This should not be considered a quarterly scientific progress report. Instead, in this field OMB requests a description of the overall purpose and expected outputs and outcomes or results of the award and first-tier subawards, including significant deliverables and, if appropriate, units of measure. For NIH grantees, in situations where there are no significant changes from the Award Description field, then it is acceptable to say “As defined in the Award Description field” in order to avoid redundancy. Otherwise include only any significant changes. NIH grantees should also briefly note whether the grant is being transferred or relinquished in this field, as applicable.

Please note that in accordance with discussions with OMB on improving the usefulness of information for the public, all responses in the Quarterly Activities/Project Description field (as well as other narrative description fields) should at a minimum be in complete sentences; explain all abbreviations or acronyms that may be unfamiliar to the general public; and should provide clear and complete information on the award’s purpose, scope and nature of activities, location, cost outcomes, and status of activities.
How should I report a foreign vendor payment of $25,000 or more if they do not have a US ZIP code or DUNS number?
In order for your report to be successfully submitted you must enter either a US ZIP code or DUNS number for the vendor. In some instances, such as purchases of certain research equipment from foreign vendors, it may be appropriate to use the ZIP code or DUNS number of the vendor’s U.S.-based importer or U.S.-based subsidiary. If that is not possible, then the foreign vendor must obtain a DUNS number free of charge by contacting Dun and Bradstreet through their website at http://fedgov.dnb.com/webform or by phone at 1-866-705-5711. Registration is brief and can be completed immediately when requested by phone, or within 1-2 business days when requested through the webform.

D. Job Creation Estimates

What is the difference between a job created and a job retained?
For the purposes of ARRA reporting there is no difference. Jobs are to be reported as a ''full-time equivalent'' (FTE), calculated quarterly as all hours worked and funded by the Recovery Act during the current reporting quarter divided by the total number of hours in a full-time schedule for the quarter, as defined by the recipient or federal contractor. For more information on how to perform this calculation, please see OMB Memorandum M-10-08, found at http://www.whitehouse.gov/omb/assets/memoranda_2010/m10-08.pdf.
Are "Jobs Created" and "Jobs Retained" reported separately?
No. These are combined as a single data element titled "Number of Jobs" in the OMB Data Model. Even if the prime recipient delegates other reporting responsibilities to the sub-recipient, the Number of Jobs data element is not separately reported by the sub-recipient.
Who reports the job figures for sub-recipients�prime recipient or sub-recipients?
This will be the responsibility of the prime recipient to report as a single, combined number.
How are full-time, part-time and temporary jobs reported?
The estimate of the number of jobs required by the Recovery Act should be expressed as "full-time equivalents" (FTE), which is calculated as total hours worked in jobs created or retained divided by the number of hours in a full-time schedule, as defined by the recipient (see pages 35-36 of the OMB guidance document for more information). The FTE estimates are not cumulative and must be reported for the current reporting period only.
Can percentage effort be used to measure FTEs instead of hours?
Yes. An alternative calculation based on the allocable and allowable portion of activities expressed as a percentage of the total is acceptable for recipients of assistance agreements that must comply with OMB Cost Principles (such as Circular A-21, Cost Principles for Educational Institutions and circular A-122, Cost Principles for Non-profit Organizations). For example, a full-time faculty member charging 50% effort on an ARRA award will be counted as .5 FTE. Hourly and part-time employees shall be calculated based on actual hours worked on the sponsored agreement and the institution's definition of a full workload for employment.
How are NRSA trainees/fellows counted?
Although NRSA trainees and fellows may not be considered employees of the grantee institution, for the purposes of Section 1512 reporting it is best to report these positions as Jobs Created/Jobs Retained in the "Number of Jobs" section. If you choose not to report these positions as jobs, you should note in the "Quarterly Activities/Project Description" that trainees and fellows were not included in your calculation.
Is the job figure a cumulative figure? Would you expect it to grow each quarter?
The job figure is a cumulative figure; however, the number of FTEs does not necessarily have to grow each quarter. For an example refer to page 35 of the OMB guidance document.
We received an S10 Shared Instrumentation grant and all of the money was used to purchase a large piece of equipment. How should we report the number of jobs created if all the money went to purchase the new equipment and not to salaries?
If no salary costs were covered by the grant, grantees should report zero jobs created. In addition, you should not add the number of jobs created by the vendor unless they can be directly connected to the ARRA funding and are readily available. Per OMB guidance, the number of "indirect" or "inferred" jobs created or retained by vendors should not be included.
We used all the money from our S10 to purchase a large piece of equipment; however, we also hired a technician to operate and maintain it. Can we count that as a Job Created/Retained even if no salary is charged to the S10?
NIH does not recommend this since the grant did not cover costs for personnel. However, if you do report the job, make it clear in the "Award Description" field that the award was for equipment only and explain in the "Quarterly Activities/Project Description" field that you are including the non-ARRA funded job in the "Number of Jobs" field.
Should jobs be reported for administrative supplements that were awarded solely for equipment?
In general, no, since the grant did not cover cost for personnel. Recipients should make it clear in the "Award Description" and "Quarterly Activities/Project Description" fields that the award was for equipment only.
Should consultants paid with ARRA funds by prime recipients, sub-recipients, or vendors be reported in the "Number of Jobs" field?
Yes. If you can readily obtain the information to perform the Number of Jobs calculation, it is appropriate to count consultants as Jobs Created/Jobs Retained in the "Number of Jobs" field.

E. Data Review

What is the timing of the review period?
From the 11th to the 21st of the reporting month, reports are reviewed by the prime recipients. This review is particularly critical when a prime has delegated reporting requirements to sub-recipients. If a prime recipient notes a mistake in a sub-recipient's report, they must contact the sub-recipient and have the sub-recipient make the correction. Only the party who initially submitted the report is able to make changes. NIH can see the data at this time and due to the limited time available for agency review may actually begin a preliminary review prior to the 21st. Beginning on day 22 of the reporting month, the reports are locked from further changes, and NIH has 7 days to conduct their review. If a change is needed during this period, a notification will be sent to the recipient describing the discrepancy. [Note: even if the prime recipient has delegated this reporting requirement to sub-recipients, NIH's communication will be with only the prime recipient.] This notification also serves to unlock the report so it can be changed by the recipient. Any changes must be transmitted by the 29th of the month. On day 30 of the reporting month, regardless of the review status, the reports are published on Recovery.gov.
What will NIH look for during their review of recipient reports?
NIH will initially be reviewing for material omissions and significant errors as defined in the OMB guidance document. However, we expect this to be an evolving process and will adapt our level of review as time and experience suggests.
What is the definition of a material omission?
Material omissions are defined as failure of an award recipient to report on a received award as required by the terms of the award or data in a report that is not responsive to a specific data element. Note that failure to provide the NIH Agency Code of "7529" will prevent NIH from accessing the report and will cause the missing report to be considered a material omission.
What is the definition of a significant reporting error?
Significant reporting errors are defined as those instances where required data are not reported accurately and such erroneous reporting results in significant risk that the public will be misled or confused by the recipient report in question. Examples of these include, but are not limited to:
- Amount of Award � The amount of the award listed in the report does not match the amount of award listed in our database.
- Number of Jobs � The number of jobs listed in the report falls outside the available parameters.
- Recipient Dun and Bradstreet Numbering System (DUNS) Number � The awardee DUNS number does not match the DUNS number in our database.
The "Total Federal Amount ARRA Funds Received/Invoiced" data element will not reconcile with the number that will be reported for the quarterly SF272 cash transaction report. Is that a problem?
Due to the timing of the required reports, it is recognized that the Total Federal Amount ARRA Funds Received/Invoiced figure reported for the Section 1512 quarterly report may differ from that submitted on the quarterly SF272. Grantees should report figures to the best of their knowledge and ability at the time each report is due.
Who is responsible for the quality of data submitted under Section 1512 of the Recovery Act?
Prime recipients, as owners of the data submitted, have the principal responsibility for the quality of the information submitted. The reporting requirement is a requirement of the recipient and final responsibility for the accuracy and timeliness of the data remains with the prime grantee. Sub-recipients delegated to report on behalf of prime recipients share in this responsibility. Agencies funding Recovery Act projects and activities provide a layer of oversight that augments recipient data quality. Oversight authorities including the OMB, the Recovery Board, and Federal agency Inspectors General also have roles to play in data quality. The general public and non-governmental entities interested in "good government" can help with data quality, as well, by highlighting problems for correction.
Is NIH required to certify or approve data for publication on Recovery.gov or agency Web sites?
No. NIH is required to run a data quality review process consistent with Sections 3 and 4 of the OMB guidance document. These actions are expected to occur prior to the 30th day of the reporting month. Reports will be posted on the 30th day after the end of the quarter regardless of the outcome of NIH data quality review efforts.
How will issues identified under the data quality reviews be communicated to the public?
Federal agencies will be required to classify submitted data using the following three categories:
- Not Reviewed by agency;
- Reviewed by agency, no material omissions or significant reporting errors identified; and
- Reviewed by agency, material omissions or significant reporting errors identified.
Within the third category, to the extent the agency identifies any data that it has reason to believe is false or misleading that has not been corrected by the recipient or sub-recipient, the Federal agency must provide such findings to [email protected] so that the Recovery Board can make such instances public on the Web site www.Recovery.gov.

The system will automatically default to the first category of "Not reviewed by agency" if an agency has not chosen one of the above three categories before the 29th day of the process.

F. Questions Specific to NIH Administrative Supplement Programs

Are recipients of ARRA Supplements and Competing Revisions required to file a quarterly report?
Yes, you must report on ARRA-funded administrative supplements, summer research experience supplements, and competing revision awards.
An administrative supplement for the summer research experience covers the summers of 2009 and 2010. Does the grantee need to report on the quarters in between the two summers when no activity will be ongoing?
Yes. However, it would be appropriate to show no change in activity for elements such as progress, amount expended, and number of jobs during the months between the two summers.
Can the abstract of the parent grant be used in the "Award Description" field for an administrative or summer research experience supplement?
No. A short description should be written that reflects the purpose of the supplement though it may reference the parent as applicable. For summer research experience supplements, you could provide a sentence such as, "This grant provided a summer research experience(s) for ___________________ (insert "X" number of high school student(s), college student(s), science educator(s), etc.) in health-related scientific research."
Do multiple ARRA supplements to the same parent grant need to be reported separately?
Yes. A separate report for each separate award (S1, S2, etc.) is expected. Although funds for these supplements can be drawn down together from the HHS Payment Management System (PMS), each supplement is issued as a unique award and often will have a distinct budget/project period. It is also expected that each supplement will have a different Award Description.
I received a supplement for equipment and made the purchase. Should I write "fully completed" in the "Project Status" field? Do I need to make additional quarterly reports for the duration of the budget/project period?
If you choose "fully completed" for the "Project Status" field, the total amount of ARRA expenditures must equal the total amount of award. In this case, you should enter "yes" in the "Final Report" field. This will close the award record and no further expenditures can be reported in the ARRA quarterly report. No further ARRA quarterly reporting is required.
What are the special quarterly reporting requirements for ARRA-funded supplements to ARRA-funded parent awards?
The terms and conditions for these awards allow institutions 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 reports these in a single 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.

Also see: NIH Staff ARRA FAQs (NIH Staff Only)

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This page was last reviewed on April 6, 2009