April 2, 2021
NOT-OD-18-107 - NIH Enforcement of Closeout Policies
NOT-OD-15-136 - Impact of Discrepancies Between Final Financial Reports for Grant Closeout
NOT-OD-15-135 - Grant Closeout: Deadlines for Financial Drawdowns and Reporting in PMS
NATIONAL INSTITUTES OF HEALTH (NIH)
The intent of this Notice is to remind recipients of the deadlines for drawing funds from the Payment Management System (PMS) and the process for reconciling errors. Recipients may request payments from PMS up to 120 days past the period of performance end date, to liquidate obligations incurred during the period of performance. Per the NIH Grants Policy Statement (NIHGPS), a term and condition of every NIH award, recipients must submit timely, accurate final grant expenditure reports, and reconcile cash transaction reports submitted to the PMS with expenditure reports submitted to NIH.
A recipient may draw funds up to the date that its Final Federal Financial Report (FFR) is due to NIH or up to 120 days past the period of performance end date (see NOT-OD-15-135); PMS will automatically reject any request made after 120 days past the period of performance end date. Before submitting FFRs to NIH, recipients must ensure that the information submitted is accurate, complete, and consistent with the recipient's accounting system (see NIHGPS Section 126.96.36.199.2). When submitting the FFR through PMS, the Authorized Organization Representative (AOR) or the individual designated to submit this report on behalf of their institution, certifies that the information in the FFR is correct and complete and that all outlays and obligations are for the purposes set forth in grant documents, and represents a claim to the Federal government.
Additional Time Required for Orderly Closeout
Recipients must submit a final FFR, Final Research Performance Progress Report (RPPR), and Final Invention Statement and Certification within 120 calendar days of the end of the period of performance (see NIHGPS Section 8.6). In the event that additional time is needed to fulfill the closeout requirements (e.g. prepare, revise, or amend financial reports), a no-cost extension should be requested. The NIH Standard Terms of Award provide the recipient the authority to extend the final budget period of a previously approved project period one time for a period of up to 12 months beyond the original completion date down in the Notice of Award (NoA). Any additional project period extension beyond the initial extension of up to 12 months requires NIH prior approval. The request should include a description of the project activities (e.g. preparation of closeout reports) that require support during the extension and a statement about the funds available to support the extension (see NIHGPS Section 8.1.2).
In rare cases, a recipient may need to revise or amend previously submitted expenditures more than 120 days past the period of performance end date in order to revise a previously submitted FFR. In these cases, the AOR must notify the IC Grants Management Specialist listed in the NoA for additional guidance (see NIHGPS Section 188.8.131.52.3). The notification must indicate why the revision is necessary and describe what action is being taken by the recipient to preclude similar situations in the future. If an adjustment is to be made, the NIH awarding Institute or Center (IC) will advise the recipient of actions it will take to reflect the adjustment.
Please note that when the revision results in a balance due to NIH, the recipient must submit a revised report whenever the overcharge is discovered, no matter how long the lapse of time since the original due date of the report. This should be done as promptly as possible, but no later than 1 year from the due date of the original report for annual FFRs and no later than 60 calendar days from the due date of the original report for final FFRs (i.e., 180 days from the project end date).
Division of Grants Policy
Office of Policy for Extramural Research Administration (OPERA)
Office of Extramural Research