NIH Closeout Procedures (From the PI Perspective)

Now that you are nearing the end of your NIH project do you know how to properly close out the award?

When you accept an NIH grant you are agreeing to the terms and conditions included in your Notice of Award.  The terms include the NIH policy requiring submission of three types of final reports no later than 120 calendar days after the termination of the grant. Here’s a refresher on the NIH Closeout requirements.

Steps to Closeout

The guidelines for completing the Closeout of your grant are located on the final Notice of Award from NIH under Section III – Standard Terms and Conditions.  Additionally, an NIH Grants Closeout Specialist will send an email to you and to the Office of Sponsored Programs (OSP) with a reminder to submit the final reports.  The reports to be submitted are:

  1. Final Federal Financial Report (Final FFR SF-425) – The FFR is submitted to NIH by our Research Grants and Contracts (RGC) office through the Payment Management System (PMS).
  • Research Administration Services (RAS) Completes the financial report using the ART tool and routes a pdf copy to RGC through the Salesforce ticketing system.
  • A unique case number is assigned to the request, and any included attachments are routed to the assigned RGC analyst.
  • The RGC analyst reviews and routes the FFR to the assigned Associate Director for submission through the PMS portal. A copy of the completed financial report is emailed to both the initiator of the Salesforce ticket and RAS leadership.

NOTE:  The PI is generally not involved in the preparation and submission of the Final FFR unless there are questions on expenditures.  RAS and RGC handle this report on behalf on the PI.

  1. Final Research Performance Progress Report (FRPPR) – The Final RPPR is required for any grant that will not be extended to a new competitive segment.
  • The PI, with the support of RAS, creates the F-RPPR in eRA Commons (For instructions and screen shots, see https://era.nih.gov/erahelp/commons/default.htm#Commons/status/closeout/Final_RPPR.htm%3FTocPath%3DRPPR%2520Module%7C_____6)
  • PIs may contact their RAS unit to determine which OSP Analyst should receive the F-RPPR or consult the OSP website at http://osp.emory.edu/about/dept-listing.html to determine the appropriate Grants Analyst assigned to their department.
  • The PI must route the F-RPPR to the OSP analyst in eRA Commons so that the OSP analyst has access to submit the report. In addition, to the PI must email both the RAS and the OSP Analyst to alert them to the F-RPPR and let them know ] it is final and ready to submit to NIH.  (This email is an essential step, as F-RPPRs do not route in EPEX, so the email is the only notification that it is ready to submit.)
  • The OSP Analyst reviews and submits the F-RPPR to NIH. The PI will receive an email from eRA Commons once the F-RPPR is submitted.

NOTE:  The PI is a critical participant in this report as only the PI can fully document the scientific accomplishments and results of the project.

NOTE:  For information on which report to submit when you are applying for a competing continuation, see https://grants.nih.gov/grants/forms/report_on_grant/final_progress_reports.htm

  1. Final Invention Statement (HHS 568) (FIS) – The FIS form should be completed in eRA Commons
  • The PI initiates and completes the FIS in eRA Commons (For instructions and additional information, see https://era.nih.gov/erahelp/commons/default.htm#Commons/status/closeout/final_inven_stmt.htm?Highlight=FIS)
  • eRA Commons will send an automatic notification that the FIS was uploaded to OSP
  • The Sponsored Research Analyst (OSP) will verify that the information disclosed on the report matches information in the files maintained by the Office of Technology Transfer (OTT).
  • If the two reports match (the FIS and OTT file), OSP will submit the FIS to NIH in eRA Commons.
  • If the two reports do not match, OSP will work with the PI to reconcile the difference. This often requires the PI to revise the FIS in eRA Commons to match the information in OTT’s files, which reflect invention disclosures previously made to NIH. Once the reports are reconciled and the information is consistent across systems, OSP will submit the final report to NIH.

NOTE:  The PI is a critical participant in this report as only the PI knows whether there were inventions conceived or first actually reduced to practice during the course of work under the project, whether previously disclosed or not and regardless of the status of any patent.  Completing the FIS and marking “NONE” is the PI’s confirmation that no inventions were created.

When all the reports have been submitted to NIH, you will be able to log into the Closeout Status screen in eRA Commons and confirm that NIH has received or verified the reports.  (https://era.nih.gov/erahelp/commons/default.htm#Commons/status/closeout/closeout.htm?Highlight=closeout )

If the grant is a Fellowship or a Training grant, a fourth report is also required.  In addition to the reports above, you must also submit the following (Fellowships being transferred to another institution may require confirmation of financials to be reviewed by RAS/RGC):

  1. Termination Notice (PHS 416-7) – The Termination Notice (TN) for both Training Grants and Fellowships is submitted through xTRAIN in eRA Commons.
  • The PI or Fellow initiates the TN in xTRAIN and populates the required information. (For detailed instructions see, https://era.nih.gov/files/xTrain-Termination-of-Fellowships.pdf)
  • The PI or Fellow routes the completed form to the Business Official (BO) selected from the drop-down list. Depending on the PI’s department, the BO will be either Brian Miller, Xiaowen Ma, or Carlos Salinas.   The PI can find out which BO to select from their RAS Analyst, and RGC will verify that the correct BO is selected.
  • The BO creates Salesforce ticket to RGC analyst responsible for verifying that the information on the form, including the amount of stipend paid to the fellow, matches internal records.
  • RGC will work with RAS to address any questions or issues. If the form needs to be updated, the BO routes the form back to the PI for revision. (If no action is taken by the PI in 14 business days, the system will route the form to the BO).
  • Once corrections are made, RGC approves the TN and routes it to NIH for final approval.

NOTE:  You will not see the status of the Termination Notice on the Closeout Status screen.

Termination notices should be submitted within 30 days of the termination date even if the fellow is not available for signature.

Please ensure section eight: summary of training/education received during the appointment is completed by the fellow/trainee on all submissions. Additionally, if the appointment is being terminated early a justification is to be included in this section and the stipend claimed must be prorated to the early termination period. 

Additional resources to complete NIH Award Closeouts:

https://grants.nih.gov/grants/closeout/index.htm

https://grants.nih.gov/grants/policy/nihgps/HTML5/section_8/8.6_closeout.htm

https://nexus.od.nih.gov/all/2021/04/27/reminder-of-nih-closeout-policies/

https://era.nih.gov/files/xTrain_Terminations.pdf

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