NIH Enforcement of Closeout Policies

NIH Notice Number: NOT-OD-18-107 Key Dates
Release Date: November 30, 2017

Related Announcements
NOT-OD-17-085
NOT-OD-17-022
NOT-OD-15-136
NOT-OD-15-135
NOT-OD-15-111
NOT-OD-14-084
Issued by
National Institutes of Health (NIH)

Purpose

The purpose of this Notice is to alert the NIH extramural community that NIH is strengthening enforcement of longstanding closeout requirements, outlined in the NIH Grants Policy Statement Section 8.6, Closeout. NIH has consistently reminded recipients of their responsibility to submit timely, accurate final grant expenditure reports, and has communicated the critical need for recipients to reconcile cash transaction reports submitted to the HHS Payment Management System (PMS) with expenditure reports submitted to NIH.  In order to fulfill agency requirements under the Grants Oversight and New Efficiency (GONE) Act and HHS grants policy, NIH will no longer delay the closeout of awards unless the recipient submits a prior approval request to the IC providing an acceptable written justification..  Without prior approval from the awarding IC, NIH will initiate unilateral closeout for all awards that fail to meet closeout requirements within 120 days as required by the NIH Grants Policy Statement (NIH GPS) Section 8.6. See below for details.

Background

Recipient Responsibilities

The requirement for timely closeout is generally a recipient responsibility. However, NIH may initiate unilateral closeout if a recipient does not provide timely, accurate closeout reports or does not respond timely to NIH requests to reconcile discrepancies in grant records.

NIH recipients must submit a Final Federal Financial Report (FFR), Final Research Performance Progress Report (F-RPPR), and Final Invention Statement and Certification (FIS) within 120 calendar days of the end of the period of performance (project period), as required in section 8.6 of the NIH GPS. The reports become overdue the day after the 120 calendar day period ends. Cash transaction data continues to be submitted directly to and processed by PMS. It is the recipient’s responsibility to reconcile reports submitted to PMS and to the NIH awarding Institute or Center.

NIH Actions

NIH is committed to addressing and reducing grant closeout delays and to enhance compliance with HHS regulations and policies, and the GONE Act.  Therefore, NIH will strictly enforce its closeout policies. When recipients fail to submit timely reports, NIH will initiate unilateral closeout. It is important to note that for financial closeout, if a recipient fails to submit a final expenditure FFR, HHS policy directs NIH to close the grant using the last accepted Federal Cash Transaction Report’s cash drawdown amount. This could be considered a debt or result in disallowed costs.  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.

Please direct all inquiries to: Division of Grants Policy
Office of Policy for Extramural Research Administration
Office of Extramural Research
Telephone: 301-435-0949
GrantsPolicy@od.nih.gov