1 Comments
What do these three recent notices in the NIH Guide for Grants and Contracts have in common?
- NOT-OD-24-055 – NIH Enforcement of Unilateral Closeout Reporting in the System for Award Management Responsibility/Qualification (formerly Federal Awardee Performance and Integrity Information System (FAPIIS)
- NOT-OD-24-047 – Reminder for NIH Closeout Reporting Requirements and Closeout Email Notifications
- NOT-OD-24-017 – NIH Will Send Reminder Notifications to Recipients with Final Federal Financial Reports (FFRs) in Rejected Status Beginning November 2023
They all relate to a grant recipient’s responsibility to submit timely and accurate final grant expenditure, progress, and invention reports within 120 calendar days of the end of the period of performance. These notices reinforce our commitment to doing our part by providing recipients with clear guidance, reminders, and system notifications of required actions, as well as, strictly enforcing regulations through unilateral closeout and reporting to SAM.gov when those actions aren’t taken.
From the first time you drew down funds from an award, you vowed to adhere to the terms and conditions of award, including timely administrative and financial reporting, until closeout do us part.
Resources
In regards to Final and Interim RPPR submission compliance it would be helpful for NIH to impose restrictions on individual PI’s rather than on the Institution. Have any late Final or Interim RPPR’s ? Consider adding to your policies that any current grant proposals will not be considered for funding until PI works to get the late Final/Interim progress reports submitted. Central administration has better control over FFR reporting because expenditures can be monitored and reported, but we can’t write the scientific progress. I know NIH will echo everything is the institution’s responsibility, but consider this a joint enforcement action that would assist in bringing about better overall compliance. It would also be helpful to see where institutions are generally failing the most in the 3 separate reports FFR,FRPPR or FIS that lead to a Unilateral Closeout. I see no individual consequences in this blurb below and I can only say I would welcome them:
NIH Actions
NIH is committed to addressing and reducing grant closeout delays and to enhance compliance with Federal regulations and NIH policies. Therefore, NIH will strictly enforce its closeout policies. When recipients fail to submit timely reports, NIH will initiate unilateral closeout. If a recipient does not submit all required closeout reports within a year of the period of performance end date, NIH will unilaterally close the award and report the recipient’s failure to comply with the terms and conditions of award in SAM.gov. In addition, failure to correct recurring reporting problems may cause NIH to take one or more actions that may include, but are not limited to, corrective actions, withholding of further awards, suspension or termination per Section 8.5.2 of the NIH GPS.