Step 6: Post-Award Administration

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There are many requirements that recipient organizations need to be aware of to ensure they are successful stewards of federal funds. NIH publishes policy updates in the NIH Guide for Grants and Contracts as well as updates to Funding Opportunity Announcements (FOAs). You should reference the NIH Grants Policy Statement and the Notice of Award (NoA) often for details on all post-award processes and requirements.

Find the latest grant policies

Monitoring

The grants management specialist (GMS) and program director continuously monitor the grants in their portfolio through the review and assessment of information gathered from audit reports, progress reports, financial reports, site visits, correspondence, and peer review.

Recipients are required to have financial systems in place to monitor their grant expenditures. NCI grants management staff monitors individual grants within each budget period and within the overall project period. The rate and types of expenditures are expected to be consistent with the approved project and budget based on an assessment of the effort to be performed during that period. The GMS reviews recipient cash expenditure reports to determine whether they indicate a pattern of accelerated or delayed expenditures. Expenditure patterns may indicate a deficiency in the recipient’s financial management system or internal controls. Accelerated or delayed expenditures may result in a recipient’s inability to complete the approved project within the approved period of performance. NCI allows some flexibility for rebudgeting, but there are specific guidelines and limitations.

The names, titles, and telephone numbers of the responsible GMS and Program Director are included in the NoA.

Under federal regulation 45 CFR 75.364, the HHS awarding agency, Inspector General, the Comptroller General of the United States, and the pass-through entity, or any of their authorized representatives, have the right of timely and unrestricted access to any books, documents, papers, or other records of recipients that are pertinent to the grant awards in order to make audits, examinations, excerpts, transcripts, and copies. The recipient is also required to allow timely and reasonable access to personnel for the purpose of interviewing and discussing these documents. The rights of access are not limited to the required retention period, but last as long as records are retained.

When problems or weaknesses are found, NCI staff work with the applicant or the recipient institution to resolve the issues. It is usually possible for a mutually agreeable course of action to be worked out so that the award process can proceed. However, it may be necessary for the Grants management officer (GMO), designated specialist, and/or program director to visit the applicant or recipient institution(s) in order to evaluate scientific progress, management systems, and adequacy of policies, procedures, and controls if:

  • Problems or weaknesses are found to be severe enough to threaten the ability of the principal investigator or the recipient institution to administer and/or complete the research project for which the grant was awarded
  • The applicant organization refuses to adopt required assurances and certifications that reflect national social and economic policy
  • The recipient fails to comply with the terms of award. NCI staff may then take any of the following actions:
    • Not issue the new or competing renewal award
    • Withhold the next noncompeting renewal award
    • Adjust the level of support awarded
    • Place restrictions and/or special conditions on the award
    • Pay recipients on a reimbursement rather than an advance basis
    • Suspend or terminate the active grant

Prior Approval Requests

In general, NIH recipients are allowed a certain degree of latitude to rebudget within and between budget categories to meet unanticipated needs and to make other types of post-award changes. Some changes may be made at the recipient’s discretion as long as they are within the limits established by NIH. In other cases, NIH prior written approval may be required before a recipient makes certain budget modifications or undertakes particular activities. Circumstances in which prior approval is required include but are not limited to:

  • a change in scope of the project,
  • extensions beyond the allowable 12 month period,
  • change in status of key personnel,
  • change of recipient organization,
  • deviation from award terms and conditions,
  • foreign component added to a grant to a domestic organization,
  • or a need for additional NIH funding.

All requests that require prior approval must be made in writing (email is acceptable) to the grants management officer at least 30 days before the proposed change. If the Authorized Organization Representative (AOR) is not sending the request, it must be endorsed by him/her; a cc to the AOR is not acceptable. Requests must be clearly identified as prior approval requests and include the grant number in the subject line. The GMO will review the request and provide a response to the AOR with copies to the PD/PI and the NCI program director. Only responses from the GMO are considered valid. Recipients that proceed on the basis of actions by unauthorized officials do so at their own risk.

Failure to receive prior approval may result in enforcement action such as the disallowance of costs or termination of award or other actions within agency authority. Questions should be directed to the grants management specialist designated in the NoA.

Rebudgeting

The recipient institution is permitted to rebudget between budget categories within the total costs awarded to meet unanticipated requirements, provided the expenditures:

  1. Are within the scope of the approved project
  2. Enhance and do not impede the successful continuation or completion of the project
  3. Are allowable under governing regulations and policies

Some rebudgeting actions may require specific prior approval from the NCI. The NIH Grants Policy Statement and the terms of the award should be consulted regarding current policies on rebudgeting and prior approval authority. The grants management specialist assigned to the project may also be contacted for advice.

Auditing

In general, recipients who expend $750,000 or more in federal awards are required to have an annual audit performed by a public accountant or a federal, state, or local government audit organization that meets generally accepted government auditing standards. Organizations expending less than $750,000 during the fiscal year are not required to have an annual audit.

Educational institutions and nonprofit organizations including hospitals are subject to the requirements of the Uniform Guidance at 2 CFR 200.

For-profit organizations, including for-profit hospitals and foreign organizations, can satisfy audit requirements with either of two types according to the 45 CFR 75.501(i).

  • A financial related audit as defined in and in accordance with, the Government Auditing Standards, GPO Stock #020-000-00-265-4 the “Yellow Book.”
  • An audit that meets the requirements of 45 CFR Part 75.

This audit should include review of the internal controls that are maintained to provide reasonable assurance that:

  • Financial operations are properly conducted
  • Financial reports are presented fairly and accurately
  • Applicable laws, regulations, and other grant terms have been complied with
  • Resources are managed and used in an economical and efficient manner

Desired results and objectives are being achieved in an effective manner

The federal government may, at its discretion, review the internal accounting and other control systems during or after NIH support of the grant activity.

See Audit Requirements for specifics related to submitting the annual audit.

Annual Reporting Requirements

Recipients must submit a variety of reports during the lifecycle of a grant award. All reports must be accurate, complete, and submitted on time. Below is a list of the most common reports required, but it is not all-inclusive. Recipients must review their individual award requirements and the NIH Grants Policy Statement to ensure compliance.

Research Performance Progress Report (RPPR)

A (RPPR) is required at least annually as part of the non-competing continuation (Type 5) award process and it must be submitted through the eRA Commons. Only the PI or their delegate may initiate an RPPR in the eRA Commons. If there are multiple PIs, only the Contact PI (or their delegate) may initiate the report. The report must be submitted and approved by NCI Program and Grants Management staff prior to receiving funding for each subsequent budget period within a previously approved competing project period. The Notice of Award (NoA) will specify if a progress report is due following a different schedule.

Learn more about RPPR

Invention Reports

Regulations require that recipient 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. Recipients are expected to use the Interagency Edison system (iEdison).

Federal Financial Report (FFR)

Reports of expenditures are required as documentation of the financial status of grants according to the official accounting records of the recipient organization. NIH requires all financial expenditure reports to be submitted using the FFR system in the eRA Commons.

  • Both cash transaction data and expenditure data are required to be submitted.
  • Cash transactions are reported on a quarterly basis and expenditure data is primarily reported on an annual basis.
  • Except for awards under SNAP and awards that require more frequent reporting, annual reports must be submitted for each budget period no later than 90 days after the end of the calendar quarter when the budget period ended.
  • If more frequent reporting is required, the frequency and due date will be specified on the NoA.

Other factors related to a specific grant may add additional reporting requirements. These requirements will be specified in the NOA. Grants management staff review and monitor the submission of these requirements.

Grant Appeals

HHS permits recipients to appeal certain post-award adverse administrative decisions made by HHS officials (see 45 CFR 16 and appendix to part 16). NIH has established a first-level grant appeal procedure that must be exhausted before an appeal may be filed by the recipient with the Departmental Appeals Board (DAB) (see 42 CFR 50, Subpart D). NIH will assume jurisdiction for the following adverse determinations set forth in 42 CFR 50.404:

  • Termination for Cause or Convenience, in whole or in part, of a grant for failure of the recipient to carry out its approved project in accordance with federal statutes, regulations, assurances, an application, a Notice of Award, or terms and conditions of a federal award
  • Determination that an expenditure not allowable under the grant has been charged to the grant or that the recipient has otherwise failed to discharge its obligation to account for grant funds
  • Denial (withholding) of a noncompeting continuation award for failure to comply with the terms of a previous award
  • Determination that a grant is void (i.e., a decision that an award is invalid because it was not authorized by statute or regulation or because it was fraudulently obtained)

The formal notice of an adverse determination from the IC will contain a statement of the grantee’s appeal rights. In the first level of appeal, the grantee must submit a request for review to the NIH official specified in the notification detailing the nature of the disagreement and providing supporting documents in accordance with the procedures provided in the notification.

If the NIH decision on the appeal is adverse to the recipient or if the request for review is rejected on jurisdictional grounds, the grantee has the option of submitting a request to the Departmental Appeals Board (DAB).

For additional information, see the NIH Grants Policy Statement, Grant Appeals Procedures.

Transfer of a Grant

NIH prior approval is required for the transfer of the legal and administrative responsibility for a grant-supported project or activity from one legal entity to another before the expiration of the approved project period (period of performance). A change of recipient organization may be accomplished under most NIH grants, including construction grants. A change of recipient that involves the transfer of a grant to or between foreign institutions or international organizations must be approved by the IC’s Advisory Council or Board.

  • A grant to an individual may not be transferred. However, an individual fellowship may be transferred to a new sponsoring organization. The transfer process will be the same as for a change of recipient organization
  • A change in an individual fellow’s department or sponsor within the same organization is not considered a change of recipient organization.
  • A successor-in-interest or a name change is not considered a change of recipient.
  • A change of recipient organization may involve the transfer of equipment purchased with grant funds. The transfer may be accomplished as part of the original recipient’s relinquishment of the grant; otherwise, the NIH reserves the right to transfer title to equipment to the new organization as indicated in Administrative Requirements—Management Systems and Procedures—Property Management System Standards."
  • The NIH may request additional information necessary to accomplish its review of the request. Acceptance of a relinquishing statement by NIH does not guarantee approval of a transfer application for the continued funding of a project.

Record Retention

By the Recipient

Financial and programmatic records, supporting documents, and all other records that are required by the terms of a grant must be retained by the recipient as follows:

Awards Not Under SNAP Three years from the date the final annual FFR is submitted to the NIH
Awards Under SNAP (except those to foreign organizations and federal institutions) Three years from the date the FFR for the entire competitive segment is submitted to the NIH. This rule applies to all records for the entire competitive segment
Foreign Organizations and federal Institutions Must submit annual expenditure reports for all awards, including those under SNAP, and must retain records for these awards, including those under SNAP, for three years from the date of submission of the annual FFR to the NIH

If an audit or other action is in process at the expiration of the three-year retention period, the records are to be retained until all issues arising from the audit have been resolved by the NCI.

By the NCI

In general, official grant records are retained for six years.

Construction grant records are retained for 20 years.

If a grant is involved in an appeal or litigation, the retention period begins when the case is closed. There is a three-year retention period for unfunded applications that begins upon notification to the applicant that an award will not be made or upon withdrawal of the grant application.

Grant Closeout

The grant closeout process is initiated as soon as grant support ends. Recipients are required to submit all closeout documentation using the eRA Commons no later than 120 days after the expiration of the project period or after the grant transfers to a new institution. If the grantee is delinquent submitting grant closeout reports, the NCI may initiate a Unilateral Closeout action. This is a serious action for the grantee institution and can impact future funding.

Learn more about grant closeout.

  • Posted: April 2, 2015