Additional Short-Term Administrative Relief to Institutions Impacted by Hurricanes Harvey, Irma, and Maria

Notice Number: NOT-OD-18-114

Key Dates
Release Date: December 12, 2017

Related Announcements
NOT-OD-18-002
NOT-OD-17-113
NOT-OD-17-111

Issued by
National Institutes of Health (NIH)

Purpose

The NIH would like to announce additional short-term administrative relief that is available in the areas affected by Hurricanes Harvey, Irma, and Maria.

Working with the Office of Management and Budget (OMB), and the Department of Health and Human Services (HHS) we have identified the following actions to relieve short-term administrative, financial management and audit requirements under the Uniform Guidance at 2 CFR Part 200 “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” which are implemented in HHS regulation at 45 CFR Part 75 without compromise to accountability requirements.

Flexibility with application deadlines.

  • Although NIH's general policy is to accept applications submitted late due to a natural disaster by no more than the number of days the applicant organization was officially closed, due to the catastrophic damage caused by the Hurricanes we deemed it necessary to provide additional exceptions and guidance.
  • We will accept late applications from these impacted institutions for all funding opportunity announcements with dues dates between September 16 and December 16, 2017 (see NOT-OD-17-111 and NOT-OD-18-002), no later than 11:59 PM December 16 (local applicant organization time), regardless of how many days the applicant organization was officially closed.
    • Note: NIH is now extending this broader flexibility to institutions impacted by Hurricane Irma as well as Hurricanes Harvey and Maria.
  • We encourage a cover letter explaining the reason for late submission but these letters are not required.

Extension of financial and other reporting.

  • As noted in NOT-OD-17-111 and NOT-OD-18-002, if you are unable to complete and submit progress reports, financial reports, and/or invention reports by the scheduled due date, contact the assigned grants management and/or program official to let them know the reports will be late.
    • Update: Annual and quarterly financial and performance reports may be submitted up to three (3) months beyond the normal due date.
  • Although NIH will accept these late reports, we will delay issuing grant awards until the required reports are submitted and accepted by NIH. This does not prevent the institution from receiving disaster relief supplemental funding, if those funds become available.

Prior approval requirement waivers.

  • As a reminder, you already have rebudgeting authority available under NIH Grants Policy Statement Sec. 8.1.1.2:, which states, “NIH prior approval is not required to rebudget funds for any direct cost item that the applicable cost principles identify as requiring the Federal awarding agency's prior approval, unless the incurrence of costs is associated with or is considered to be a change in scope.”

Extension of currently approved Facilities and Administration (F&A/indirect cost) rates.  

  • For grantee institutions whose current Federally approved F&A rates are close to expiring (i.e., in the next several months, but less than a year from now), NIH will allow grantees in the affected areas to continue to use the current Federally-approved indirect cost rates (predetermined, fixed, or provisional rates) to recover their F&A/indirect costs on Federal awards for one additional year without submission of an indirect cost proposal.
  • NIH will also approve grantee requests for an extension of the F&A/indirect cost rate proposal submission (for up to one year) to finalize the current rates and establish future rates.

Extension of Single Audit submission.

  • Per 45 CFR 75.501, institutions expending $750,000 or more in Federal funding in a Fiscal Year (FY) are required to submit an annual Single Audit report.
  • NIH will allow grantees to delay the completion and submission of the Single Audit report for up to 12 months beyond the normal due date.
  • The delayed completion and submission would still qualify the grantee as a “low-risk auditee” under the criteria of 45 CFR 75.520.

Alternatives for record retention and cost documentation.

  • We will allow grantees to substitute copies of original records for the original records, as permitted under 45 CFR 75.363.

Expenditure of award funds for salaries and other project activities.

  • Remember that, in general, expenditure of award funds to continue paying salaries and fringe benefits to researchers during any period when no work is performed under the award is unallowable.
  • However, if your organization’s policy allows it to continue to charge salaries and benefits to currently active Federal awards (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal, then you would be able to continue charging salaries for those budgeted on current NIH grants.
    • Note: NIH awarding Institutes/Centers (ICs) may request documentation for confirmation of such an institutional policy.

Extension of Closeout

  • We are allowing grantees to delay submission of any pending financial, performance and other reports required by the terms and conditions of award for the closeout of expired projects, provided that proper notice about the reporting delay is given by the recipient to the agency. This delay may not exceed one year.

NIH is also allowing grantees to use unobligated balances on their active grants for immediate recovery efforts, including such efforts to sustain or move animals, cell lines, reagents, etc. This is an allowable cost as long as it’s within the scope of the original award. Additionally, NIH will allow “significant rebudgeting” (i.e., 25% or more change across budget categories) without prior approval, as long as there is no change to scope (i.e., scientific aims).

Please see the Recent Natural Disaster Events FAQs for additional guidance.

NIH is continuing to monitor the situation, identifying ways we can help as outlined on this page, and will publish any additional information pertaining to these natural disasters in the NIH Guide.

Inquiries

Please direct all inquiries to:


Division of Grants Policy
Office of Policy for Extramural Research Administration
Office of Extramural Research
Telephone: 301-435-0949
[email protected]
https://grants.nih.gov/grants/natural_disasters.htm

and

Division of Receipt and Referral
Center for Scientific Review
Telephone: 301-435-0715
Email: [email protected]