NOT-OD-14-084: NIH Updating Grant Closeout Policies and Procedures to Align with New HHS Requirements

NIH Updating Grant Closeout Policies and Procedures to Align with New HHS Requirements

Notice Number: NOT-OD-14-084

Key Dates
Release Date: April 24, 2014

Issued by
National Institutes of Health (NIH)

Purpose

The purpose of this Guide Notice is to inform grantees that NIH will revise certain policies and procedures in the closeout of NIH grants and cooperative agreements to strengthen accountability, monitoring and oversight of closeout activities for grants with project end dates after September 30, 2014.

Background

The U.S. Department of Health and Human Services (HHS) has issued a directive to Agencies on new policies for closeout of grant awards. NIH will revise its policies and procedures to align with that guidance and improve administrative efficiencies in its closeout processes.

No changes are expected to the current NIH Standard Terms of Award provision allowing grantees to initiate a one-time, no-cost extension in the last year of the award. In addition, all final reports needed to close a grant (financial, progress, and inventions statement/certification when applicable) will continue to be due within 90 days of the project end date.

Anticipated Changes

Anticipated changes will focus on condensing the timeframe for reconciling discrepancies between financial expenditures and cash transactions reports and for resolving other post-submission issues affecting acceptance of the final Federal Financial Report (FFR). Current NIH policy allows the submission of a revised final FFR within 15 months of its original due date. New HHS policy initially provided a shorter timeframe. However, the Office of Management and Budget (OMB) recently published Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards; Final Rule (Uniform Guidance) that provides agencies a longer timeframe in which to close awards than would have been allowed under new HHS policy. Therefore, NIH is awaiting further guidance from HHS on department wide implementation, including whether the HHS timeframe will be adjusted to align with the Uniform Guidance.

Grantees are advised that financial reconciliation upon completion of an award includes ensuring that the balances of expenditures and unobligated funds reported on the final expenditure FFR match those amounts as reported in the last federal cash report submitted to PMS. New HHS policy stipulates that if the NIH cannot undertake a bilateral closeout i.e., closeout with the cooperation of the grantee within 180 days of the project end date, it must initiate unilateral closeout i.e., closeout without receipt of acceptable final reports or for those grantees that are not in compliance with the policy. It is important to note that for financial closeout, if a grantee fails to submit a final expenditure FFR, new HHS policy directs NIH to close the grant using the last recorded cash drawdown level. NIH is also awaiting further guidance from HHS on whether this timeframe will be adjusted. If the grantee submits a final expenditure FFR but does not reconcile any discrepancies between expenditures reported on the final expenditure FFR and the last cash report to PMS, NIH is required to close the award at the lower amount. This could be considered a debt or result in disallowed costs.

NIH has posted a web page with Frequently Asked Questions (FAQs) on grant closeout. We will provide further guidance to the community as additional information becomes available from HHS and changes are announced.

Inquiries

Please direct all inquiries to:

Division of Grants Policy
Office of Policy for Extramural Research Administration (OPERA)
Office of Extramural Research
National Institutes of Health
Telephone: 301-435-0949
Email: [email protected]