LATE FINANCIAL STATUS REPORTS NIH GUIDE, Volume 22, Number 10, March 12, 1993 P.T. 34 Keywords: Grants Administration/Policy+ National Institutes of Health Recipients of Public Health Service (PHS) nonconstruction grants are required to submit the Financial Status Report (SF 269 or 269A) as documentation of the financial status of grants according to the official accounting records of the grantee organization. Department of Health and Human Services (HHS) regulations at 45 CFR Part 74.73(d) and Part 92.41(b) dictate that the FSR, when required on an annual basis, must be submitted for each budget period no later than 90 days after the close of the budget period. The late submission of the FSR is a continuing problem for the PHS and the National Institutes of Health (NIH). While some grantees are in full compliance with this requirement, many are not. In fact, NIH data show that 45 percent of the FSRs submitted during fiscal year 1992 arrived after the 90 day period. Late submission of FSRs is not only a violation of HHS regulations, but also may be an indication that grantee accounting systems are deficient in meeting the federal accounting standards required by the Office of Management and Budget. The subsequent effort and follow-up on the part of the Division of Financial Management (DFM) and the NIH awarding components to obtain delinquent FSRs is time-consuming and labor-intensive for all parties. DFM regularly sends out a listing of past due financial status reports to all grantee institutions, informing them of their current status. The latest report was mailed out in early January. Staff at the NIH strongly believe that submission of timely FSRs is critical. Therefore, we want to work with you to identify the reasons for poor performance in the past and the steps that can be taken now to improve future performance. The NIH is beginning specific reviews of organizations that have been severely delinquent or overdue in the submission of FSRs. These institutions will be requested to review their systems with a critical eye to recognize the causes for late or delinquent FSRs, whether due to insufficient staffing, inadequate computer systems, or problems with accounting or organizational structure. These institutions will have to develop and submit a plan that identifies the problems experienced by the institution that have prevented timely submission of FSRs in the past; outlines the steps that will permit the institution to develop the capability for submitting future FSRs on time, including a timeline with milestones for improvement; and details the steps that will be taken in order to submit currently delinquent reports. If performance is not improved, these institutions may be in jeopardy of having sanctions imposed upon them until the problems are corrected. It is extremely important that grant recipients submit financial reports within the required time period. Failure to comply with this requirement may lead to delays or withholding of awards, loss of automatic carryover authority, loss of advanced payments, loss of expanded authorities, removal from participation in NIH-funded awards under the Federal Demonstration Project, and designation as a high- risk grantee. Grantees should evaluate their record for submitting FSRs as well as their current status. If FSRs are being submitted late, prompt corrective steps must be taken. If necessary, outside technical assistance should be obtained. It is important to reiterate that delinquency and lateness are serious concerns for all institutions and administrative authorities may be withdrawn from any institution that exhibits systemic problems or chronic lateness. In an effort to assist the grantee community, the NIH has developed a system for the Electronic Transmittal of Financial Status Reports, an interactive computer-based communications system. It enables the electronic transmission of FSRs from the grantee organization to the NIH mainframe computer. The electronic process eliminates the manual preparation, mailing, and handling of the hard-copy FSR, as well as manual processing once it arrives at NIH. There are several advantages derived from the use of this system: FSRs transmitted via this system are processed within 72 hours; the system gives users immediate feedback because it can detect errors; electronically submitted FSRs cannot be lost in the mail or sent to the wrong address; and users of the system can access current listings of grants for which FSRs are past due or for which FSRs will become due as of a specified period of time (terminating grants). INQUIRIES Additional information about the electronic system may be obtained by contacting Richard Rhoads or Priscilla Irick NIH Division of Financial Management Telephone: (301) 496-5287 .
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