Revised Policy on Applicant Institution Responsibilities for Ensuring Just-in-Time Submissions are Accurate and Current Up to the Time of Award

Notice Number: NOT-OD-10-120

See Notice NOT-OD-03-029.

Update: The following update relating to this announcement has been issued:

Key Dates
Release Date: September 13, 2010

Issued by
National Institutes of Health (NIH)


Ensuring the accuracy and timeliness of information used to make NIH grant awards is an important responsibility shared by both applicant institutions and NIH staff.  Equally important is the need to collect this information in a manner that reduces the burden on applicants and minimizes the number of requests from NIH staff for updated Just-in-Time information.   To achieve these goals, NIH is issuing this Guide Notice revising and clarifying the responsibilities of applicants and NIH staff to ensure that such information submitted to NIH is current and accurate at the time of award. 


Responsibilities of Applicant Institutions:

NIH grant applicants are responsible for verifying the accuracy and validity of all administrative, fiscal, and programmatic information at the time of submission.  This notice extends that policy to information submitted through the Just-in-Time process.  Applicants are responsible for promptly notifying NIH of any substantive changes to previously submitted Just-in-Time information up the time of award. This includes items such as Other Support changes that could lead to budgetary overlap, scientific overlap, or commitment of effort greater than 12 person-months for the PD/PI(s) or any Senior/Key Personnel; or any changes in the use or approval of vertebrate animals or human subjects. Similar to the NIH public policy requirements, applicants are responsible for establishing and maintaining the necessary processes to monitor its compliance with this policy and informing NIH of any problems or concerns. 

Recent changes to the eRA Commons Just-in-Time Submission Module have improved the electronic process by allowing individual submissions of each required element separate from other elements, and by providing the new capability to submit updated information electronically as many times as necessary.  

Responsibilities of NIH Staff:

NIH staff rely on applicant institutions to provide updated Just-in-Time information in a timely manner.  Any such submission will be considered current by NIH for use in making final award decisions for a period up to 120 days from the time of the submission.  During this period, NIH staff will normally not require or request any additional information from applicants unless the submission is considered inaccurate or incomplete.  On a case by case basis NIH staff may also request additional JIT information be submitted through the “Other Upload” function, such as revised budgets or changes to either the human subjects or vertebrate animals sections of the proposed project. Failure by applicants to address changes to Just-in-Time submissions prior to award (such as a change in status of the PD/PI(s) or Senior/Key Personnel, or changes in the use or approval of vertebrate animals or human subjects) does not diminish the applicant’s responsibility to address changes post-award by submitting a prior approval request to NIH in accord with the NIH Grants Policy Statement and the Terms and Conditions of Award.

Reminder of Existing Just-in-Time Requirements:

Several elements of a grant application are not required at the time the application is submitted. Instead, this information will be requested later in the review cycle (i.e., “just-in-time”) to ensure that it is current. The information eligible for just-in-time submission includes:

Applicants are advised to submit this information (signed by an authorized business official) only when requested by the awarding component. Applicants are strongly encouraged to submit this information using the Just-In-Time feature of the eRA Commons found in the Status section. For information on the eRA Commons visit:


For general inquiries concerning this policy contact:

Division of Grants Policy
Office of Policy for Extramural Research Administration
National Institutes of Health
6705 Rockledge Drive, Suite 350
Bethesda, MD 20892
Telephone: (301) 435-0938
FAX: (301) 435-3059

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