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Post-Award Monitoring and Reporting
If you are the recipient of a grant from the NIH, there is a great deal of information that your organization will need in order to be successful stewards of federal funds. The NIH Welcome Wagon Letter provides information and resources for new grantee organizations on how to manage the award.
The information provided below is a brief overview of selected monitoring and reporting requirements. For full details on any of these topics, see the NIH Grants Policy Statement. For specific questions, consult first with the administrative officials within your organization. The assigned NIH program officials and grants management specialists are available to answer any remaining questions.
Grantees are responsible for managing the day-to-day operations of their grant. To fulfill their role as a steward of federal funds, NIH awarding offices monitor grants to identify potential problems and areas where technical assistance might be necessary. This active monitoring is accomplished through review of reports and correspondence from the grantee, audit reports, site visits, and other information available to NIH.
The Department of Health and Human Services grant payments may be made by one of several advance payment methods, including SMARTLINK II/ACH, CASHLINE/ACH, or cash request, or by cash request on a reimbursement basis, as specified in the NoA. Additional information on payment methods is in the NIH Grants Policy Statement.
Applicant organizations are required to have financial systems in place to monitor their grant expenditures. NIH monitors grantee expenditures under individual grants within each budget period and within the overall project period. The funding that NIH provides for each budget period is based on an assessment of the effort to be performed during that period and the grantee's associated budget, including the availability of "un-obligated" balances. Although NIH allows its grantees flexibility with respect to re-budgeting (see Administrative Requirements—Changes in Project and Budget in the NIH Grants Policy Statement), NIH expects the rate and types of expenditures to be consistent with the approved project and budget and may question or restrict expenditures that appear inconsistent with these expectations.
The Grants Management Specialist (GMS) reviews grantee cash expenditure reports to determine whether they indicate a pattern of accelerated or delayed expenditures. Expenditure patterns are of particular concern because they may indicate a deficiency in the grantee's financial management system or internal controls. Accelerated or delayed expenditures may result in a grantee's inability to complete the approved project within the approved budget and period of performance. In these situations, the GMS may seek additional information from the grantee and may make any necessary and appropriate actions.
Prior Approval Requests
All requests that require prior NIH approval must be made in writing (e-mail is acceptable) to the Grants Management Officer at least 30 days before the proposed change. The request must be endorsed by the Authorized Organization Representative. Failure to obtain required prior approval from the appropriate NIH awarding office may result in the disallowance of costs, termination of the award, or other enforcement action within the NIH's authority.
If you have questions, contact the grants management specialist or the program official named in your NoA.
NIH requires grantees to submit a variety of reports which are due at specific times during the life cycle of a grant award. All reports must be accurate, complete, and submitted on time.
NIH requires grantees to submit Research Performance Progress Reports (RPPR) through the eRA Commons at least annually as part of the non-competing continuation award process. The progress report must be approved by NIH to non-competitively fund each budget period within an approved project period.
The RPPR asks grantees about accomplishments towards the goal of the project, plans for the next year of the project, manuscripts and publications produced, personnel who have worked on the project, changes to level of effort of key personnel on the project, actual or planned challenges or delays in the projects and plans for resolving them, significant changes regarding human or animal subjects, inclusion enrollment reports for clinical studies, and more.
Regulations require that grantee organizations report all inventions to the awarding agency (see NIH Grants Policy Statement), as well as include an acknowledgement of federal support in all patents. Grantee organizations must use the Web-based Interagency Edison system (iEdison) to comply with the Bayh-Dole Act and related intellectual property reporting requirements.
Final Invention Statement
When a grant is completed and a subsequent competing segment is not funded, or when a grant is transferred from one institution to another, a Final Invention Statement and Certification (HHS 568) must be submitted to the NIH within 120 days. For grants that are closing out, the Final Invention Statement and Certification can be submitted along with the other required closeout documents through the eRA Commons. For transfers, the HHS 568 should be submitted directly to the NIH awarding Institute or Center. A downloadable version of the HHS 568 is avilable here or: https://s-edison.info.nih.gov/iEdison/hhs568.pdf.
Financial Reporting (Institutional Requirement)
Financial reporting is accomplished using the Federal Financial Report (FFR) (SF-425/SF-425A).
Federal Financial Report (SF425) Cash Transaction Reports.
Cash transaction data is submitted on a quarterly basis directly to the Payment Management System (PMS). For more information on cash transaction reports, see the Division of Payment Management's Web site.
Federal Financial Report (SF425) Expenditure Data Reports
Expenditure data is required as documentation of the financial status of grants according to the official accounting records of the grantee organization.
Except for awards under the Streamlined Noncompeting Award Process (SNAP) and awards that require more frequent reporting, the FFR expenditure data is required on an annual basis. Annual expenditure data is required for awards to foreign organizations and federal institutions, whether or not they are under SNAP. When required on an annual basis, the report must be submitted for each budget period no later than 90 days after the end of the calendar quarter in which the budget period ended. The report also must cover any authorized extension in time of the budget period. If more frequent reporting is required, the NoA will specify both the frequency and due date.
Quarterly Cash Transaction Reports (PSC 272)
NIH grantees or sub-recipients that expend $750,000 or more in federal awards during the fiscal year are subject to an audit requirement. Organizations expending less than $750,000 during the fiscal year are not required to have an annual audit for that year, but must make their grant-related records available to NIH or other designated officials for review or audit.
Audits shall be completed and submitted to the designated offices shown below within a period that is either the earlier of (1) 30 days after receipt of the auditor's report(s), or (2) nine months after the end of the audit period (i.e., the organization's fiscal year).
Federal Audit Clearinghouse
Bureau of the Census
1201 East 10th Street
Jeffersonville, IN 47132
For-profit organizations, including for-profit hospitals, and foreign organizations should submit their audit report directly to:
National External Audit Review Center
HHS Office of Audit Services
1100 Walnut Street, Suite 850
Kansas City, MO 64106-2197
NIH closes out a grant as soon as possible after the project period end date if the grant will not be extended of if continued funding is not provided. Closeout consists of the timely submission of all required reports and adjustments for amounts due the grantee or NIH. Closeout of a grant does not automatically cancel any requirements for property accountability, record retention, or financial accountability. Following closeout, the grantee remains obligated to return funds due as a result of later refunds, corrections, or other transactions, and the federal government may recover amounts based on the results of an audit covering any part of the period of grant support.
Required closeout reports include:
- Final FFR Expenditure data
- Final progress report
- Final Invention Statement and Certification
- Final population tracking data when applicable
Instructions for submitting the Final Progress Report are part of the PHS 2590, Section 3. All close out reports are due within 120 days of the end of grant support. Failure to submit timely and accurate final reports may affect future funding to the organization or awards with the same PD/PI.
Learn more about Closeout.
Grantees generally must retain financial and programmatic records, supporting documents, statistical records, and all other records that are required by the terms of a grant, or may reasonably be considered pertinent to a grant, for a period of 3 years from the date the annual FFR is submitted. For awards issued under the SNAP authorities, the three-year retention period is calculated from the date the FFR is submitted for the entire competitive segment.
Closeout may also affect the time period for retention of records by the grantee, because the three-year record retention period begins with the submission of the final FFR. See 45 CFR Part 74.53 and 45 CFR Part 92.42, Retention and Access Requirements for Records.