Guidance on Enforcement of Closeout Requirements During the Appeals Process
Notice Number:
NOT-OD-25-128

Key Dates

Release Date:

July 7, 2025

Related Announcements

None

Issued by

NATIONAL INSTITUTES OF HEALTH (NIH)

Purpose

The purpose of this notice is to provide the extramural community with guidance on enforcement of standard closeout requirements on NIH grants and cooperative agreements during the agency priorities grant appeals pre-award procedures. NIH terminated awards due to activities that do not align with the NIH mission and agency priorities, timely submission of an appeal may impact the recipient’s ability to complete all closeout requirements within the timeframes provided in the revised Notice of Award. NIH is still in the process of reviewing and responding to appeal submissions related to recent terminations. Some have received responses and others have not, which has placed the recipient at risk for noncompliance with closeout requirements to no fault of the recipient.

Therefore, NIH is alerting the extramural community that, in cases where a recipient has submitted an appeal, but has not yet received a response, NIH will not take action to initiate unilateral closeout while the appeal is under review. We will document our compliance records and ask that the community use this notice as supporting documentation to prevent an audit finding related to closeout.

Finally, please disregard language within the termination letters and/or subsequent Notice of Awards requiring recipients to comply with closeout timelines that do not align with NIHs standard processes found in the NIH Grants Policy Statement, 8.6 Closeout that requires recipients to submit the final Federal Financial Report, final Research Performance Progress Report, and Final Invention Statement and Certification within 120 calendar of the end of the period of performance. 

Inquiries

Please direct all inquiries to:

NIH Office of Policy for Extramural Research Administration

[email protected]