New Prior Approval Capability Joins Suite of Options in eRA Commons

A new type of prior approval is available to NIH recipients in eRA Commons as of October 12, joining a menu of other prior approval requests.  Recipients of NIH awards are now required to use the ‘Other Request’ type in Prior Approval to submit any changes to their approved Data Management and Sharing Plan (DMS Plans) to NIH officials (see NIH Guide Notice NOT-OD-23-185 and eRA news item).

In the eRA Commons’ Prior Approval module:

• On the Prior Approval screen, select “Other Request” and a table will list eligible awards.
• Click “initiate” on the eligible award to initiate an Other Request type.
• Fill out the Prior Approval Other Request screen.
  • Description. Enter “DMS Plan Revision” (without quotations).
  • Effective Date. Enter the effective date of the requested changes.
  • Justification Document. Provide the rationale and justification for the requested changes.
  • Budget Document. Provide if the revised DMS Plan impacts the budget. Include information for current and future budget periods. Note: This is not a supplement request.
  • Other Supporting Documents. Attach the revised DMS Plan.  
• All uploaded documents must be in PDF format.

Only a signing official can submit the request. For NIH awards, this functionality may only be used for revised DMS Plan prior approval requests.  

Other Capabilities in Prior Approval

In addition to the ‘Other Request’ type, here are five situations where applicants and/or recipients seeking prior approval from the funding agency can do so using the Prior Approval module in eRA Commons:

• Withdrawal of application — Want to withdraw an error-free application before it proceeds to council, the second level of peer review?
  • A signing official (SO) or principal investigator can initiate the request using the Prior Approval module in eRA Commons.
  • The process requires a justification and up to 10 supporting documents can be uploaded with the request.
  • Only an SO can submit the request.
    
    
• Request for No Cost Extension — Traditionally, NIH allows a recipient organization to use its one-time authority to submit a notification for a No Cost Extension (NCE) — a one-time extension of the project period by up to 12 months without requesting extra funding.  This is provided the Notice of Award does not prohibit the extension and the project’s approved scope will not change.

An organization may need a No Cost Extension outside of this traditional method:

• Maybe the one-time authority has already been used.
• Or the terms of award did not originally allow this option.
• Or the project period end date has passed but the award has not yet been closed.

In any of these circumstances, the organization’s signing official can initiate and submit the NCE request using the Prior Approval module in eRA Commons.

• Request for Carryover — Say an organization has unobligated federal funds remaining at the end of any budget period that they would like to carry over to another budget period. Recipients are allowed to carry over funds automatically if they have the expanded authority as noted on their Notice of Award. For all others, the SO needs to submit a prior approval request for carryover to their respective grants management specialist(s) and program official(s), who will review the request. To be eligible for a carryover:
  • The grant must be still active.
  • The grant should not have expanded authority.
  • The request data should be within the current budget period date.
  • The grant is not a Fellowship application.

• Request for Change of Principal Investigator — Under some scenarios, a recipient organization may need to remove or add a Program Director/Principal Investigator (PD/PI) to a research project.

Only the SO can initiate and submit the Change of PD/PI request and the request can only be made for a grant year that is currently awarded, and within the budget period.

• Request for $500k or more in Direct Costs — If an applicant organization is planning to submit a grant application with $500,000 or more in direct costs in any one budget year [excluding consortium Facilities & Administration (F & A) costs], it needs to obtain approval from the funding agency 6 weeks prior to application submission.
  • The organization should contact their program official (PO). The PO will – depending on internal review — initiate an invitation and send to the principal investigator, who can look up the request in the Prior Approval module.
  • After filling out the fields on the Prior Approval Request 500k screen, entering the justification, anticipated submission date of the application and uploading any supporting documents, the PI can route the request to the SO to submit.