NIH Implementation of the Interim-RPPR while a Renewal Application is Under Consideration

Notice Number: NOT-OD-17-037

Key Dates
Release Date:  January 19, 2017

Related Announcements
NOT-OD-17-085
NOT-OD-17-022

Issued by
National Institutes of Health (NIH)

Purpose

This Notice is directly linked to NIH’s implementation of the Final-RPPR. NIH retains the renewal application policy and in order to do so, we will implement an Interim-RPPR policy to reduce administrative burden on grantees by not requiring an additional Final-RPPR if the renewal application is not funded. See below for details.

NIH previously announced the requirement for organizations to submit an Interim Research Performance Progress Report (Interim-RPPR) while their renewal application is under consideration. Therefore, the purpose of this notice is to update the timeframe for implementation of the Interim-RPPR from what was stated in NOT-OD-17-022 and provide further clarification for reporting when the current competitive segment is ending but a renewal application has been, or will be, submitted. In addition, this notice explains how NIH will subsequently treat a submitted Interim-RPPR to fulfill reporting requirements on the competitive segment that is ending once the disposition of the renewal application is known.

NIH Implementation

Effective February 9, 2017, if the recipient organization has submitted a renewal application on or before the date by which a Final Research Performance Progress Report (Final-RPPR) would be required for the current competitive segment, then submission of an "Interim-RPPR" via eRA Commons is now required.   Based on this requirement, the NIH will discontinue the policy for renewal applications whereby, “whether funded or not,” the progress report contained in the renewal application may serve in lieu of a separate final progress report. 

Like the Final-RPPR, recipients will be required to adhere to the new requirement to report on Project outcomes in the Interim-RPPR. This section will be made publicly available, thus allowing recipients to provide the general public with a concise summary of the cumulative outcomes or findings of the project (analogous to the Project Summary/Abstract section of the competing application) at the end of a competitive segment.

An Interim-RPPR link for the grant will appear in the Status tab in eRA Commons after the period of performance end date has passed. In the event that the renewal application is funded, NIH will treat the Interim-RPPR as the annual performance report for the final year of the previous competitive segment. If the renewal application is not funded, the Interim-RPPR will be treated by NIH staff as the institution's Final-RPPR. 

As stated in NOT-OD-17-022, the Interim-RPPR must be submitted via the eRA Commons no later than 120 calendar days from the period of performance end date. If a recipient fails to comply with this reporting requirement, NIH may take one or more enforcement actions, such as a decision to withhold a non-competing continuation award, consistent with NIHGPS Chapter 8.5.2. NIH will maintain the business rule in the RPPR module enabling institutional signing officials (SOs), at their discretion, to delegate submission of the Final RPPR or Interim-RPPR to the Program Director/Principal Investigator (PD/PI).

Further guidance is provided through the scenarios below outlining the process of when to submit a Final or Interim-RPPR.

Scenario

Status of Competing Renewal Application

Workflow Process

1

Competing Renewal not submitted

Submit a Final-RPPR no later than 120 calendar days from the period of performance end date.

2

Competing Renewal submitted

Submit an Interim-RPPR no later than 120 calendar days from the period of performance end date. If the competing renewal is funded, NIH will treat the Interim-RPPR as the annual performance report for the final year of the previous competitive segment.

3

Competing Renewal submitted but not funded

Submit an Interim-RPPR no later than 120 calendar days from the period of performance end date. If the competing renewal is not funded, NIH will treat the Interim-RPPR as the institution's Final-RPPR. To reduce burden NIH will not require recipients to submit an additional Final-RPPR if the renewal application is not funded.

Reminder: Effective January 2017, NIH requires recipients to report on Project Outcomes in Section I of the Interim and Final-RPPR. Therefore, in each scenario listed above, Project Outcomes must be provided by the recipient in order for the recipient to submit their final report in eRA Commons. Otherwise, eRA Commons will not allow recipients to submit the required report and recipients will be considered non-compliant.

Implementation of the Final RPPR for Small Business Innovation and Research (SBIR) and Small Business Technology Transfer (STTR) grants will occur approximately 2 months after implementation for all other NIH grants due to unique final reporting requirements under the Small Business Administration's SBIR/STTR Policy Directive.

Inquiries

Please direct all inquiries to:

Division of Grants Policy
Office of Policy for Extramural Research Administration
Office of Extramural Research
grantspolicy@od.nih.gov