NOT-OD-14-103: Revised Timeline for Administrative Changes to NIH Domestic Awards to Transition to Payment Management System Subaccounts

Revised Timeline for Administrative Changes to NIH Domestic Awards to Transition to Payment Management System Subaccounts

Notice Number: NOT-OD-14-103

Key Dates
Release Date: July 11, 2014

Issued by
National Institutes of Health (NIH)

Purpose

This Notice alerts grantees to a change in the implementation timeline, previously announced in NOT-OD-13-120 and NOT-OD-14-093, for the NIH transition to new U.S. Department of Health and Human Services (HHS) payment policies for domestic, non-competing continuation awards and use of Payment Management System (PMS) subaccounts. It also announces a change in how competitive revisions/administrative supplements (Type-3s) awards will be processed.

This Notice only applies to domestic non-competing continuation awards that have not yet transitioned to PMS subaccounts. In response to critical feedback from the grantee community, NIH requested an amendment to its subaccount implementation plan to delay the transition of domestic, non-competing continuation awards to PMS subaccounts for an additional year; e.g., now beginning October 1, 2015. HHS’s Office of the Assistant Secretary for Financial Resources recently approved the request. This additional time is provided to allow grantees to prepare their systems to accommodate the changes. Grantee with inadequate systems in place to appropriately manage this transition by October 1, 2015, may be unable to appropriately access PMS accounts and risk losing their ability to draw down funding. Grantees are advised that there will be no additional implementation delays considered and no exceptions granted to the deadline. As of October 1, 2015, NIH will utilize only subaccounts for awarding grant funds. Every grant that is awarded funding in FY 2016 (whether it be in the first, second, third or fourth quarter of FY 2016) will be in a subaccount.

NIH will continue transitioning payment of grant awards with new document numbers to domestic institutions to PMS subaccounts in FY 2015 as announced in Notice NOT-OD-13-120. The administrative changes announced in NOT-OD-14-093 will now apply to the transition that will occur between October 1, 2015 and September 30, 2016. This Notice reiterates those administrative changes for non-competing, continuation awards and highlights the revised implementation timelines and T-3 award process for all domestic awards.

Revised Implementation Timeline

The transition of all NIH awards to PMS subaccounts is anticipated to be complete by September 30, 2016.

Implementation for Domestic Awards with New Document Numbers
NIH will continue to transition payment for all domestic awards with new document numbers (i.e., Type 1, Type 2, Type 4, Type 6, Type 7, and Type 9) from PMS pooled accounts (G accounts) to PMS subaccounts (P subaccounts). For these types of awards, PMS will establish subaccounts for each NIH award made on or after October 1, 2013. All subsequent non-competing continuation awards to these grants will also be issued in subaccounts.

Implementation for Domestic Type 3 Awards
Please be aware that beginning with awards issued on/after October 1, 2015, competitive revisions/administrative supplements (Type 3s) issued to domestic awards, will now also be issued in a P subaccount. This is a change from the previously announced plan and is regardless of whether the parent grant is still in PMS pooled accounts (G accounts) or has transitioned to PMS subaccounts (P subaccounts).

Implementation for Domestic, Non-Competing Continuation Awards
Implementation for domestic, non-competing awards has been delayed by one fiscal year; this implementation will now occur between October 1, 2015 and September 30, 2016. NIH will transition payment for all continuing domestic awards (i.e., Type 5 and Type 8) awards that have not yet transitioned to subaccounts from PMS pooled accounts (G accounts) to PMS subaccounts (P subaccounts). For these types of awards, PMS will establish subaccounts for each NIH award made on or after October 1, 2015.

For domestic grants with a non-competing continuation year of funding in fiscal year (FY) 2016 (October 1, 2015 September 30, 2016), NIH will use a technical process to shift the funding from PMS G accounts to PMS P subaccounts by issuing all FY 2016 non-competing continuation awards that have not yet transitioned to subaccounts as Type 4 awards (funded extension awards). This means that all domestic Type 5 awards (non-competing continuation awards) and Type 8 awards (non-competing continuation awards with a change of awarding Institute or Center), will be issued as Type 4s during the transition period.
In addition to changing the record Type and the document number for the FY 2016 award, NIH will change the project period end date of the FY 2015 award when the FY 2016 award is issued. The project period end date will be changed to the budget period end date. This effectively breaks the single competitive segment into two shorter "administrative segments." The change will be reflected in the eRA Commons; however, NIH will not issue a revised Notice of Award (NoA) for the FY 2015 award.
Therefore, the FY 2015 award becomes the final year of the first "administrative segment" and requires Federal Financial Report (FFR) expenditure data, which is a Subaccount Transitional FFR.
Records for non-competing continuation progress reports (Type 5s), or in rare instances Type 8s, that have not yet transitioned to subaccounts will be converted to Type 4s. The conversion will be processed internally by NIH.

Applicable Policies for Non-Competing Continuation Awards

Due Date for Subaccount Transitional FFR: the due date for Subaccount Transitional FFR expenditure reports is no later than 90 days after the end of the calendar quarter in which the budget period ended.
Unliquidated Obligations on the Subaccount Transitional FFR: if there are unliquidated obligations at the end of the first "administratively shortened" competitive segment, these may be reported on the subaccount transitional FFR expenditure data report.
Subaccount Transitional FFR for converted SNAP awards: If the award is under Streamlined Non-competing Award Process (SNAP), the grantee will be required to submit subaccount transitional FFR expenditure data that covers the project period from the original start date through the new project period end date.
Due Date for Progress Reports: There will be no change to the due dates, submission, or review of progress reports for domestic awards for FY 2016.

Please see below for procedural changes in carryover of funds for non-competing continuation awards issued in FY 2016.

Change in Process to Carryover Funds and Federal Financial Reports for Domestic Non-Competing Continuation Awards during FY 2015 (October 1, 2015 September 30, 2016)

Non-competing continuation progress reports (Type 5s), or in rare instances Type 8s, that were converted to Type 4s to accommodate the change in method of payment from the pooled accounting to subaccounts, require a final FFR for the prior year(s) of the competitive segment before any carryover funds would be available for drawdown in the PMS. However, this requirement does not change the carryover authority listed in Section III of the NoA. If the award was issued with automatic carryover authority, OFM will automatically authorize the carryover in the PMS P subaccount equal to the amount of unobligated balance reported on the FFR.* If the award was issued without carryover authority, OFM will automatically transfer the unobligated balance reported on the FFR to the PMS P subaccount; however, the grantee will still be required to submit a prior approval request to use carryover funds as detailed in the NIH Grants Policy Statement, Section 8.1.1.1. If the request is approved, a revised NoA reflecting the approved carryover amount will be issued and the authorized amount will be reflected in PMS. Failure to submit FFR expenditure data in a timely manner may affect future funding.

*In accordance with existing policy, the GMO will review unobligated balances in excess of 25 percent of the total authorized amount for the budget period and may request additional information from the grantee. If the GMO determines that some or all of the unobligated funds are not necessary to complete the project, the GMO may restrict the grantee’s authority to automatically carry over unobligated balances in the future, use the balance to reduce or offset NIH funding for a subsequent budget period, or use a combination of these actions. The GMO’s decision about the disposition of the reported unobligated balance will be reflected in the terms and conditions of the NoA.

Frequently Asked Questions

NIH will post updated answers to frequently asked questions on the transition to PMS subaccounts on the following site: https://grants.nih.gov/grants/payment/faqs.htm based on this revised timeline.

Inquiries

Please direct all inquiries to:

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