Submitting Subaward Budgets That Are Not Active for All Periods of the Prime Grant
I’m often asked how to fill out the R&R Budget form for a subaward which isn’t active for all the budget periods of the prime applicant. Answering that question recently became a bit trickier. We’ve discovered a disconnect between our application guide instructions and the current behavior of our systems. Section 4.8 of our General Application Guide SF424 (R&R) - Forms Version C instructs users to line up the budget period dates and ignore the budget period numbers, while our application processing systems ignore the dates and align the budget period numbers. Yikes – that’s a problem!
In the end, we’ve decided to align the budget period numbers and will update our application guide instructions in the next iteration accordingly. In the meantime, we’ve outlined the revised instructions in NOT-OD-15-073: Correction to Application Guide Instructions for Subawards Not Active in All Budget Periods of the Prime Applicant.
Explicitely including all budget periods in every subaward budget form provides a visual indication to staff and reviewers when no activity is taking place in a specific budget period. It also streamlines the calculations necessary to determine whether an application falls within any direct cost limits. Which brings me to my next topic…
How to Tell If Your Application Falls Within a Specified Direct Cost Limit
NIH established a policy in 2004 to allow applicants to exclude consortium/contractual F&A costs when determining compliance for any application where a direct cost limit applies (see NOT-OD-05-004). When we moved to electronic submission and the federal-wide R&R Budget form, we even coded a fancy calculation that grabs the F&A costs from each subaward R&R Budget form, subtracts them from the direct costs of the main budget and provides a warning if the calculated amount exceeds what is generally allowed. Unfortunately, you had no visible indication of the calculated values we came up with since the R&R Budget forms don’t include a line item for direct costs less consortium F&A.
At the request of applicants who have submitted multi-project applications electronically and found our “Total Direct Costs less Consortium F&A” summary table helpful, we are now including a similar table in the assembled application images of NIH single-project applications that use the R&R Budget and include subaward budgets. The new table is located after the last subaward budget, has the catchy bookmark “Total Direct Costs Less Consortium F&A” and can be used to determine if your application (by NIH calculations) falls within a direct cost limit.
Of course, the calculations reflected in the table are only as good as the data provided. You must follow the instructions in NOT-OD-15-073 if you have subawards with inactive budget periods or the calculations in the table will be incorrect. Combine this nifty new table with the ASSIST “Preview Application” feature and you’ve really got something. Speaking of ASSIST…
When Can I Use ASSIST for My R01 Application?
We are already receiving a steady stream of R03 and R21 applications using ASSIST and folks seem to really like it. If you’ve tried it out and would like to share your experience, we’d love to hear from you. Just reply to this message or email me offline.
Now everyone wants to know when they can use ASSIST for their R01 applications. Throughout 2015, we’ll be opening up ASSIST as a submission option for most competing single-project applications (NOT-OD-15-044). The R01, U01, and Career Development (Ks, except K12 and KM1) activity codes are next with ASSIST support coming at the end of April (see Target Timeline for Single-Project ASSIST Support).
Remember, use of ASSIST is optional. System-to-system solutions and downloadable forms are still good options, too.
Thought of the Day
Where is the ‘Delete Winter’ button when you need it? –Unknown
To all our friends that are dealing with record snowfalls, I’m sending toasty-warm, happy thoughts your way. Hang in there – spring is just around the corner (or so I’m told).
Communications & Outreach
NIH Office of Extramural Research