11 Comments
The federal government wants your input on how to update the Research Performance Progress Report (RPPR) for use with final reports.
Federal agencies, including NIH, developed the RPPR originally as a federal government-wide solution for preparation and submission of annual and other interim performance progress reports. We are now proposing a revised format that incorporates lessons learned by agencies during our initial implementation of the RPPR and accommodates submission of both interim and final performance progress reports.
We encourage you to review the proposed format and provide comments on the Federal Register website by September 21, 2015 for consideration by the committee leading the RPPR revisions.
Stop requiring repeated input of personnel or budget information you already have. Stop allowing RPRR to refuse to get past redundant administrative questions that are already addressed in budget reconciliation by the institution at the end of year closures and stick to the point – did we or did we not make progress on the project?
Solve the problems with publications required to be linked to the report to submit by making it easy to type in recently published papers not in pubmed yet and not try to force a link in myNCBI. Later this causes problems
The amount of time spent on RPRR is far more than ever before because RPRR is too rigid and tries to fuflill too many NIH administrative mandates but does not allow for unexpected problems – this system needs to allow a PI who knows when RPRR is just plain WRONG to accept a submission with an added explanatory note. There is no “one size fits all” report, and there will always be times a rigid system fails. We need more flexibility and control as PIs. More to the point, lest get the focus back on SCIENCE.
The revised RPRR format has increased the administrative burden on investigators and on their supporting staff quite significantly. It would be worth considering if this increased burden actually provides any added benefit. Wouldn’t it be better if we could spend more time working on the projects and less on the formatting of a progress report? The last one I did was about 7 hours of effort on my part, not counting the research administrators, in trying to get the student data and ERA commons info entered without errors, and in entering information for others working on the project. The new requirements don’t change the actual “meat” of the progress report (the accomplishments section), which is where the important information is provided and is what a scientist or program officer would truly need to judge progress. It is all the other sections and requirements that were added in the RPRR process that have added seemingly unnecessary burdens and hours to the process.
The RPPR form has some elements that help to streamline progress report submission. However, overall putting together the RPPR for my non-competing training grant renewal took nearly a week to complete. Some things that would help PIs are:
1) option to allow administrative staff to log in via their own account to work on budget and other administrative pages.
2) there should be no need to enter key personnel bios for those who have era commons IDs. These individuals could be notified via email to upload their bios, animal and human subjects certifications or risk losing status on the grant.
A couple of thoughts:
1. Improve server quality to help improve end user experience. After recently submitting an interim RPPR, I had multiple experiences with server errors, pages not being saved, and being told I didn’t have the proper permissions to perform the task that was not saved.
2. It would be great to have the Participant section retain information from year to year. As a multi-site study, it is arduous to continuously re-enter the participants from the sites. The RPPR is a process and it would be more efficient to have to edit any changes, rather than add in.
3. It would also be more efficient to upload the 2590 Form for each sight and their budget justification as opposed entering in each site budget line by line.
As a reminder, while we welcome comments here, you must submit your comments to the Federal Register for consideration by the committee leading the RPPR revisions: https://federalregister.gov/a/2015-18007
What used to take a day or two now occupies me for a couple of weeks since the report gets my university grants administration deeply involved (Common ID for all the employees, etc.) I suppose the next time it may be easier since in the beginning new forms are hard to deal with. However, someone should go over the program and get the bugs out as described by others before me. Like on this form, what the heck is +3 = seven. When Jimmy Carter got rid of paper I don’t think he envisioned this form.
Leave it to government administrators to find new and creative ways to waste our time. It hate RPPR. Please make it go away.
The new RPRR is very difficult and has increased the time it takes me to prepare and submit a progress report from a few hours to a few days. PLEASE make the fields all uniform – either everything should be cut and paste OR they should be added as files, but the mix and match between these two different formats makes it extremely tedious. Before, the possibility of creating a simple PDF and submitting that was easy and straight forward. Now, I have to copy the instructions from the website, paste into a word file, write my answers, then cut that word file up into individual pdfs to upload or cut the pieces from the word file into text boxes – ARGH! My colleagues and I all use this as a perfect example of how technology has made things slower and more difficult, when it should have been the other way around.
The field for key personnel effort reporting in calendar months on the current RRPR (and the new version) only allows entry of whole calendar months i.e. 2, 3, 4 etc. However, the actual efforts to be reported are very often not whole months but are instead 2.4 or 3.6, which end up be rounded up or down to 2 or 4, as specified by RRPR instructions. In the case of rounding down this can cause problems that delay approval of the next years award because it can falsely appear that the reported effort has dropped below the minimum approved effort on the grant (i.e. more than a 25% decrease). This then leads to unnecessary inquiries from program officers and grants management specialists of whether effort has actually decreased more than allowed or not. These inquiries are major waste of time and effort for NIH program staff and the PI. This problem could easily be avoided if the new RRPR allowed actual effort reporting in 0.1 increments of calendar months so that values much closer to the actual efforts (like 2.4 or 3.6) can be reported.
I am a Signing Official who signs off on every RPPR for a large Medical School at a University. I feel like ever since the RPPR came into existence, I’m getting many more follow-up questions from Grants Management Specialists than ever before. I was very happy when the RPPR supplied a text entry field for Recipient ID. I assumed NIH would communicate back to us using that ID, but instead they continue to use their ID #. This requires us to translate and look up everything prior to determining who we notify about the issue. Please NIH, we utilize fund #’s to account for project activity and I think every institution does. If you speak in our language, we’ll speak back in your language (5-R01 etc). Additionally, it would be nice if we could include several email addresses as contacts (like business administrators who are intimately involved with the project) who would also be sent an email if there are questions from NIH. Right now NIH doesn’t consistently communicate back to everyone (AO,SO, PI and PI delegates). It should be clearly sent to the AO/SO with all other parties Cced so it is clear who needs to reply back. Too many times the PI communicates directly back and it requires AO/SO approval
Other issues that cause so many NIH inquiries:
Section B.4. Use of IDP’s. This is often overlooked by PI’s. Our School has a policy regarding the mandatory use of IDP’s and so we have to make sure we upload a statement every time we have Post Docs or Grad Students. Why not give us a check box here or better yet make it an answer we supply in our institutional profile so we don’t have to check for and individually answer this every single time.
Section C. Publications- A frustrating area for SO’s who can’t manage MyNCBI for PI’s. It seems to bring back the entire history of pubs. When the current year pubs are selected, it is temporary and reverts back to all pubs within minutes. I constantly am having to edit this for PI’s right at submission time to make it stick. This is an area often misunderstood by GMS/PO’s and PI’s who just want to see a list that doesn’t reflect “Non-compliant” pubs. PI’s continue to want to list pubs separately in Accomplishments. It just seems that if MyNCBI is the official site for maintenance of pubs related to research funding why not keep this out of the RPPR. Notify us if an award can’t be issued due to noncompliant pubs.
Section D. Participants. Perhaps the worst area of confusion solely because of the rounding. Please give us the ability to report to the nearest 10th and also let us report key personnel regardless if they are <1 CM. I get so many needless questions about this. Even the NIH FAQ's indicate that they'll figure out real effort by looking at Other Support. Problem is NIH only wants Other Support for those who have had a change in other support. When there is no change and we don't furnish OS we will get a question if the key person under 1 CM is still on the project. Then there is the appearance of a greater than 25% reduction simply because we had to round. If we can't enter 10ths than give us a text box to explain. We also often have to explain CM's better when NIH gives us a shortened budget period. No NIH FAQ deals with how to report CM's in a shortened budget period. We do know CM's are not simply a conversion of % times 12 because NIH indicates it is also a measure of time. When NIH gives a full annual budget over 9 mos is the expectation that the individual has a higher percentage in those 9 months to achieve the 12 month committed level of effort.
Speaking of Other Support- We still get PI's (including sub PI's) who think the word "Other" means every other project and do not include the reported project. We have to scan for this every time. How about changing the terminology to "All Support" to avoid confusion?
Section G
Lab animals or Human Subjects- there is no benefit in excluding approval dates. We would prefer to use them in case a protocol just expired and is in process of being renewed and we want convey that. Again, we get questions about this so why not just let us put in approval dates for each protocol.
Unobligated Balance >25%. Let us put in an estimate and explanation regardless if we answer "No". Right now the amount can only be supplied if we answer "Yes". One of the biggest reasons NIH often sees large balances is because of outstanding subcontract billings or other encumbrances. We would rather be able to be upfront and explain what you probably are seeing and what the true balance is rather than having to re-visit and answer when NIH questions us.
Section H Budgeting - On the old 2590 forms we could use the area to show our real tuition and apply the NIH formula on the request line with T's. It is preferable for institutions to show proposals for what we will get rather than providing overinflated budgets in our systems. Now we get people showing the max at 16K and NIH applying the formula to that. It would be nice if we had a text area to show our real tuition and us applying the formula.
Subcontracts - Would be nice if the amount of subcontracts entered elsewhere would feed over to line F.5.
Before accepting the RPPR as a means of communicating Final Progress, I truly hope NIH can fix these clarification issues that we are suffering from. We are getting hammered with am RPPR deadline and at the same time NIH is firing back questions on everything we already submitted imposing COB deadlines that are all over the place. My 3 top preferences for fixing:
Participants - allow reporting to nearest 10th
Unobligated - let us put in an estimated amount everytime if we want to explain
Use Recipient ID to communicate back as well as allow text entry of other email addresses to receive communication.
Thank you for this opportunity for feedback
Rich
Well, this took me MUCH longer to prepare than the old versions, and involved more admin personnel time as well- and now it looks like NIH has hired additional personnel whose jobs specifically include going over these things with fine-toothed comb and asking follow-up questions about details that NIH didn’t seemingly care about that much in the past… so if the goal was to create more administrative jobs, both at NIH and at awardee institutions, and distract investigators from their research, it has succeeded! Hopefully it will become easier to deal with as we get used to it.