NOT-OD-17-085: NIH Implementation of Final Research Performance Progress Reports (Final RPPR) for Small Business and Innovation Research (SBIR) and Small Business Technology Transfer (STTR) Grants and Cooperative Agreements

NIH Implementation of Final Research Performance Progress Reports (Final RPPR) for Small Business and Innovation Research (SBIR) and Small Business Technology Transfer (STTR) Grants and Cooperative Agreements

Notice Number: NOT-OD-17-085

Key Dates
Release Date: July 10, 2017

Issued by
National Institutes of Health (NIH)

Purpose

The National Institutes of Health will replace the SBIR/STTR Phase II Final Progress Report (FPR) with the Final Research Performance Progress Report (F-RPPR) through a new eRA Commons module effective June 30, 2017.

Background

NIH implemented the annual RPPR in 2012, based on a policy memorandum from the Office of Management and Budget and Office of Science and Technology Policy (OSTP) to the heads of executive departments and agencies establishing the uniform RPPR for use by agencies supporting research and research-related activities. The RPPR replaced previous interim performance reporting formats used by NIH and other agencies.

In order to keep its promise, the Research Business Models (RBM), an Interagency Working Group of the Social, Behavioral & Economic Research Subcommittee of the Committee on Science (CoS), charged NSF and NIH to serve as the co-chairs of an interagency workgroup tasked with developing a standard format for use in reporting final progress on Federally-funded research projects and research-related activities, taking into consideration the lessons learned from implementation of the annual RPPR. This interagency workgroup completed its task and on November 16, 2016, published a Federal Register notice announcing the updated standardized RPPR to be used for final performance progress reporting.

SBIR/STTR Phase II awards have additional unique reporting requirements prescribed by the Small Business Administration’s SBIR/STTR Policy Directive that NIH must maintain with its implementation of the F-RPPR.

NIH Implementation

NIH introduced the F-RPPR for grant closeout effective January 1, 2017. However, the F-RPPR was not implemented for SBIR/STTR grants and cooperative agreements as NIH continued technical work to incorporate SBIR/STTR Phase II reporting requirements into F-RPPR format.

Effective June 30, 2017, all SBIR/STTR Phase II final reports must be submitted using the F-RPPR. On or after that date, NIH will no longer accept FPRs for SBIR/STTR grants and cooperative agreements. Generally, SBIR/STTR recipients will find the format the same as the current annual RPPR, making it easier for recipients to navigate through the F-RPPR based on familiarity with the existing format of the annual RPPR. Likewise, there are no substantive changes to the data points contained in the SBIR/STTR Phase II FPR; rather the F-RPPR has been customized for SBIR/STTR Phase II grants to integrate those items within the F-RPPR framework.

However, a significant change with implementation of the F-RPPR, is that in order to maximize public transparency, NIH will not maintain the current Type 2 policy which in accordance with NIHGPS Chapter 8.6.2 states that "whether funded or not" the progress report contained in the Type 2 application may serve in lieu of a separate final progress report. It is important to note that the discontinuance of this longstanding policy aligns NIH's final performance reporting requirement with the requirements imposed by other Federal research awarding agencies thus reducing the administrative burden associated with a unique NIH reporting requirement.

Therefore, as a standard policy, NIH will request that organizations submit an "Interim-RPPR" while their renewal application (Type 2) is under consideration. For Phase I or Phase II SBIR/STTR grants and cooperative agreements, this means that an Interim-RPPR is required if an application for a Phase II or Phase IIB, respectively, is submitted before a final report for the Phase I award would otherwise be due. 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 Type 2/Phase II/IIB 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 Type 2 is not funded, the Interim-RPPR will be treated by NIH staff as the institution's Final-RPPR.

Also, in accordance with NIH's implementation of the F-RPPR, recipients will be required to adhere to the new requirement to report on Project Outcomes. This section will be made publicly available, thus allowing recipients the opportunity to provide the general public with a concise summary of the cumulative outcome or findings of the project (analogous to the Project Summary/Abstract section of the competing application).

As mentioned, NIH is aligning its reporting requirement with other Federal research agencies and therefore will not be making any changes to the deadline for submitting the final report- i.e., the F-RPPR or Interim-RPPR must be submitted via 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 not to make a non-competing continuation award, consistent with NIHGPS Chapter 8.5.2. NIH also plans to maintain the business rule where both the institutional signing officials (SOs), and the Program Director/Principal Investigator (PD/PI).may submit the Final RPPR or Interim-RPPR to the agency.

Scenario	Status of Phase II/IIB Application following Phase I/II Award	Workflow Process
1	Not submitted	Submit a Final-RPPR no later than 120 calendar days from the Phase I/II period of performance end date.
2	Submitted	Submit an Interim-RPPR no later than 120 calendar days from the period of performance end date. If the Phase II/IIB is funded, NIH will treat the Interim-RPPR as the annual performance report for the final year of the previous competitive segment.
3	Submitted but not funded	Submit an Interim-RPPR no later than 120 calendar days from the period of performance end date. If the Phase II/IIB 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.

Likewise for a Phase II SBIR/STTR grant, this means that an Interim-RPPR is required if an application for a Phase IIB is submitted before a final report for the Phase II award would otherwise be due and so forth for any subsequent program phases.

FAQs and additional information pertaining to NIH's implementation of the F-RPPR will be available on the NIH RPPR website and NIH’s SBIR/STTR FAQs.

Inquiries

Please direct all inquiries to:

Division of Grants Policy
Office of Policy for Extramural Research Administration
Office of Extramural Research
Email: [email protected]