Starting on October 1, 2013, NIH will begin to transition all new awards (funded with federal fiscal year 2014 (FFY14) funds) to a new “award by award” system. While originally announced that continuing awards would also begin to be issued on the new system on this date, NIH recently announced that continuing awards will not begin to be issued under the new system until October 1, 2014 for all continuation awards funded with FFY15 funds. While the later date for the transition of continuation awards reduces the previously anticipated administrative burden, the revised transition plan will still create a significant administrative burden on a number of operational areas including OSP, OGCA, departmental administrators and RAS Units. These changes will also impact PIs.
While we are still awaiting some further clarifications from DHHS and NIH, it is important that all of us are aware of the details of this notice and are actively preparing for it over the next year. This notice outlines the required transition from the pooled payment request method currently used for NIH funds to a new award specific payment request method for grantees.
Transitional Changes (for awards issued with FFY14 funding):
These changes will impact us during the transitional period of 10/1/13 – 12/31/14. Any new competitive awards that are being issued for the first year of their segment will be awarded in the new system and there will be no additional burden related to this transition to the new process for most of the community. (See “Ongoing Changes” below which do impact this population.) This change will mainly impact OGCA who will be required to drawdown and report via two systems effective 10/1/13.
Transitional Changes (for awards issued with FFY15 funding):
These changes will impact us during the transitional period of 10/1/14 – 12/31/15. During this period, continuation awards will be issued under the new system. In order to transition awards in the middle of their life cycle to this new payment method, these segments will be broken into two shorter segments. The first segment would include funding for award years issued prior to and including FFY14 which will need to be closed out (via an FFR) during FFY15. The second segment would contain any awards issued with FFY15 funding or later and will be issued under the new system. This segment will also include any funding being carried over from the previous segment (per the FFR provided for the period ending in FFY14). Below is a list of what will need to occur for these awards (issued under expanded authorities with automatic carryover authority).
The first segment will need to be fully closed out (which in the past has typically been done only at the end of five years).
- A FFR (financial report) will need to be prepared and submitted for the first segment.
- New awards/projects/smartkeys will need to be set up in Compass for the second segment.
- All payroll, HR, and service center feeder systems will need to be updated to reflect the new smartkeys.
- Subagreements will need to have a final invoice collected for the first period and be modified for the second period with a new P.O issued.
This change will not require a new grant application for awards within their life cycle. It is only a financial process/system change.
This transition, under the currently written policy changes, will require approximately 230 closeouts of awards and FFRs that were not previously required to be produced within Emory during FFY15 (which will require the closeout and setup of hundreds of Compass projects and smartkeys). Some questions regarding how carryover will be handled between these segments of awards still remain open and we are seeking further clarification from NIH. Guidance will be provided as received.
Ongoing Changes (impacts the transitional period and beyond):
Under the new policy changes, the drawdown process will be significantly more complex. In addition, funds will only remain available for 90 days following the end of the award. As a result, to avoid loss of funding, it will be necessary that all awards are reported and funding is drawn by the 90th day following the end of the award. Additional funding will no longer be available on the 91st day. This will require absolute adherence to the established deadlines set for the closeout of awards. This change will be permanent going forward for all NIH awards.
This will also require that invoices are obtained from our subawardees within 45 days of the end of the agreement (as currently written under the terms of our agreements with them). In addition, this will require that all invoices for any subawards, where we are the subrecipient, are submitted to the sponsor by approximately 45 days following the end of the award. All costs will need to be finalized on the projects by 30 days following the end of the award to allow time for preparation of the final invoice. Any feeder systems will need to have all charges booked within 30 days to ensure that they will be able to collect reimbursement for those charges.
NIH also announced that all agencies under DHHS received notification (in late August) from DHHS that they must move to this new process effective 10/1/13. While Emory has not received any communication from the other agencies, it is expected. This would include CDC, HRSA and other agencies. Information will be forwarded to the research community as it is received.
What should PIs and local administrators (departmental or RAS) be doing to prepare:
It is important that everyone (local and central administrators) stick to the deadlines outlined in the post award responsibilities guidelines that were presented at ERAZ last year and were included in the January 2013 newsletter. These can be accessed here https://blogs.emory.edu/ranews/2013/01/01/roles-and-responsibilities-for-post-award-management/. These create the map for ensuring that reports are submitted to the federal government on time and thus ensuring that we will be within the timeframe required to collect reimbursement for award expenditures.
It is very important that subcontract invoices are closely monitored and are received by the responsible department in a very timely manner (if work has been completed) so that the invoices can be processed by procurement. It is also very important that anyone who is responsible for feeder systems ensures that their systems are recording charges within 30 days (to the correct smartkey). If this does not occur, they need to understand that they may be unable to receive reimbursement for these charges.
Further guidance will be provided over the next weeks on best practices for PIs and local administrators (departmental and RAS) to ensure timely reporting and that federal funding is not a risk of loss.
Preparation Currently in Process
In an effort to prepare for these changes, the following activities are in progress:
- Currently identifying the best ways to handle this transition in Compass and Emory Express. The Compass System is currently being modified to handle these changes.
- The Award Review and Reconciliation Tool (ARRT) will be made available to all Emory Research Administrators during October 2013. Training classes are now available for registration and cover how to use this tool to conduct the final review and reconciliation at the end of the award. These classes are designed for all departmental research administrators who are involved with closing out awards. This tool is expected to assist administrators in getting the awards reviewed at the end of the award by the previously established 60 day deadline. More information about this tool can be found at https://blogs.emory.edu/ranews/2013/10/03/new-tool-coming-to-assist-departmental-and-ras-administrators-with-post-end-date-analysis/(link to ARRT article).
- OGCA is currently developing checklists and guidance documents for PIs and administrators so that everyone will clearly understand their role in ensuring that awards meet the 90 day reporting deadline.
- This change has been and will continue to be communicated broadly via a variety of different channels including at various meetings.
Since there are currently no delinquent financial reports for Emory, past cleanup of reports is not an issue that we will face. This is an additional challenge many other institutions will likely encounter.
The NIH Notice and FAQs related to it can be accessed at http://grants.nih.gov/grants/guide/notice-files/NOT-OD-13-120.html and http://grants.nih.gov/grants/payment/faqs.htm.
If you would like someone to come to a chair, faculty or staff meeting to discuss the implications and implementation of these new requirements, please contact Kerry Peluso at kpeluso@emory.edu.