·        Reminder: Mandatory Submission of the Federal Financial Report (FFR) in the Payment Management System Beginning January 1, 2021

Notice Number: NOT-OD-21-046

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-21-046.html

In alignment with HHS, NIH is implementing this change to allow recipients to report/certify expenditure data once through a single entry point and eliminate the need to report duplicative information across multiple reporting sources.

Beginning January 1, 2021, respective to NIH awards that require submission of an FFR, NIH recipients will be required to submit the FFR in the Payment Management System (PMS).  FFRs submitted prior to January 1, 2021, must use the FFR module in the eRA Commons based on the previous requirements set forth by the agency (see NIH Grants Policy Statement 8.4.1.5.2). FFRs submitted on or after January 1, 2021 must use PMS.

Training sessions offered by PMS for recipients will be posted at this link as they become available: https://pms.psc.gov/training/gr-ffr-training.html

Please refer to the guide notice linked above for more details.

If you have any questions, please contact OSP.

Clarification on Prohibition on Expending NIH Grant Funds for Covered Telecommunications Equipment or Services

Notice Number: NOT-OD-21-041

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-21-041.html

Purpose

Effective August 13, 2020, the Office of Management and Budget revised 2 Code of Federal Regulations Part 200 to align with Section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (Public Law 115-232). This new section, 2 CFR 200.216, Prohibition on certain telecommunication and video surveillance services or equipment, prohibits Federal award recipients from using government funds to procure or obtain, or enter contracts to procure or obtain equipment, services, or systems that use covered telecommunications equipment or services.

The following term of award is therefore applicable to all NIH grants and cooperative agreements issued on or after August 13, 2020. As such, this notice modifies the terms and conditions of award for grants issued on or after that date. The NIH Grants Policy Statement will be updated at the time of its next publication to incorporate this term and condition into Section 4– Public Policy Requirements, Objectives and Other Appropriation Mandates.

In accordance with the newly revised 2 CFR 200.216 and 200.471, recipients and subrecipients are prohibited from expending grant funds to:

1.       Procure or obtain;

2.       Extend or renew a contract to procure or obtain; or

3.       Enter into a contract (or extend or renew a contract) to procure or obtain equipment, services, or systems that use covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system. As described in Public Law 115-232, section 889, covered telecommunications equipment is telecommunications equipment produced by Huawei Technologies Company or ZTE Corporation (or any subsidiary or affiliate of such entities).

i.                     For the purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes, video surveillance and telecommunications equipment produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities).

ii.                   Telecommunications or video surveillance services provided by such entities or using such equipment.

iii.                  Telecommunications or video surveillance equipment or services produced or provided by an entity that the Secretary of Defense, in consultation with the Director of the National Intelligence or the Director of the Federal Bureau of Investigation, reasonably believes to be an entity owned or controlled by, or otherwise connected to, the government of a covered foreign country.

COVERED FOREIGN COUNTRY means the People’s Republic of China.

Under the National Public Policy Requirements (See NIH GPSSection 4) NIH requires applicants and recipients to certify compliance, by signing the face page of the application. The Authorized Organization Official is the responsible party for doing so. Recipients further certify compliance at the time of drawdown of funds from the Payment Management System. Recipients must maintain documentation on file to demonstrate that they have not used grant funds to procure equipment or services or enter into contracts prohibited by this part and maintain appropriate internal controls to ensure ongoing compliance. Should NIH determine non-compliance, NIH will take appropriate enforcement actions, which may include termination of award.

If you have any questions, please contact the Office of Sponsored Programs @ ospa@umbc.edu.

NIH Implementation of the Revised Federal-wide Research Terms and Conditions

Notice Number: NOT-OD-21-029

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-21-029.html

Purpose

The Office of Management and Budget (OMB) mandated awarding agencies adopt recent revisions to 2 CFR §200; Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) effective November 12, 2020. Accordingly, the Federal-wide Research Terms and Conditions (RTCs) have been revised by the participating agencies, including NIH, for consistency with the revised 2 CFR §200. The National Science Foundation hosts and maintains the RTC website on behalf of all of the participating agencies.

As outlined in the NIH Agency Implementation Statement, effective November 12th, 2020, the RTCs apply to all NIH grants and cooperative agreements with the exceptions noted in the NIH Agency Specific Requirements. NIH implementation of these Federal-wide RTCs is outlined in the NIH Grants Policy Statement, Section 3.1, and fully incorporates the revised 2 CFR §200. The RTCs serve as standard terms and conditions of all NIH awards. There are no significant changes in the requirements or terms and conditions for NIH recipients. Recipients are encouraged to review the updated documents, which include the RTC overlay, the Prior Approval Matrix, Subaward Requirements, National Policy Requirements, and the NIH Agency Specific Requirements.

Please note that the previous version of the RTCs incorporated the full set of OMB Frequently Asked Questions (FAQs) by reference. The FAQs have not yet been updated to align with 2 CFR §200, and, as such have been deleted from the RTC Overlay.

If you have any questions, please contact the Office of Sponsored Programs @ ospa@umbc.edu.

MEMORANDUM

DATE:            November 23, 2020

TO:                 Business Managers/Department Chairs/Center Directors/Faculty

FROM:           Stan Jackson

Director, Office of Sponsored Programs

RE:                 OSP deadlines over the Winter Break, Dec. 24, 2020 – Jan. 2, 2021

________________________________________________________________

This is a special announcement concerning the OSP schedule for reviewing/approving proposals with deadlines to federal and other agencies that occur during Winter Break this year. 

Please note:

1. All proposals with submission deadlines occurring between December 25, 2020 and January 3, 2021 must be fully routed, ready for submission, and released to the OSP office by close of business on December 18, 2020; and

1. All proposals with submission deadlines occurring between January 4thd and 6th, 2021 (the first 3 business days after the break) will be due to OSP by 9:00 a.m. on December 21, 2020.

This schedule is consistent with our current policy, which requires the submission of complete proposals to OSP at least three business days before the agency submission deadline. Since UMBC is closed during the Winter Break, OSP will also be closed. 

The campus closure during Winter Break will cause a heavy workload on OSP staff, so we will enforce our current policy more consistently.  Proposals received after the OSP deadlines specified above will be reviewed on a first-come/first-serve basis and will be submitted only if time permits.  In keeping with the deadline enforcement policy of OVPR, any proposal not fully routed and ready for submission by 9:00 a.m. of the deadline date will not be submitted to the agency.  If the deadline occurs over Winter Break this deadline is the last working day before the break.

Thank you for your understanding.

Please see below changes or revised procedures implemented by the National Institutes of Health (NIH).    Please take a moment to read the full Notice by clicking the link(s) below:  

NIH Summary Statement Available to the Signing Officials (SO) through the eRA Commons

Notice Number: NOT-OD-20-126

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-126.html

New process:“To facilitate award management and communications with applicant organizations via Authorized Organization Representatives (AORs), NIH has modified the system of records by adding a new routine use to clarify that information may be shared with applicant organizations.  Effective June 24, 2020, the overall impact score and the NIH Summary Statement will be made available in the eRA Commons to the Authorized Organization Representatives (AORs) of the applicant organization with the Signing Official (SO) user role in the eRA Commons.”

Upcoming Changes to the Notice of Award (NoA) Beginning October 1, 2020

Notice Number: NOT-OD-20-155

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-155.html

Changes to NoA effective 10/1/2020: “The Department of Health and Human Services (HHS) has developed a standardized Page One of the NoA and, effective October 1, 2020, this will serve as the first page of every HHS NoA for all discretionary awards.  The new Page One captures key award information for grant recipients in an intuitive and digitally accessible format and provides consistency across HHS to require fewer unique formats for HHS to manage.”

Should you have any questions, please contact OSP.

Dear Colleagues:

I want to make you aware that the following sets of NSF Award Conditions have been updated for consistency with the revised 2 CFR §200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

• Grant General Conditions (GC-1);
• Cooperative Agreement Financial and Administrative Terms and Conditions (CAFATC); and
• Cooperative Agreement Modifications and Supplemental Financial and Administrative Terms and Conditions for Major Multi-User Research Facility Projects and Federally Funded Research and Development Centers.

The revised terms and conditions will apply to all new NSF awards and funding amendments to existing awards made on or after November 12, 2020.

The terms and conditions incorporate revised 2 CFR §200 coverage including: requirements for award termination and enforcement; compliance with Section 889 of the National Defense Authorization Act (NDAA) which prohibits the use of Federal assistance funding on certain telecommunications and video surveillance services or equipment;  as well as other significant changes and clarifications.  All sets of award conditions are accompanied by a summary of changes made to that document.

NSF will separately announce the release of the Agency Specific Requirements to the Research Terms and Conditions (RTC), as well as the Administration of NSF Conference or Group Travel Award Grant Conditions (FL-26).

Questions about NSF award conditions may be sent to policy@nsf.gov.

Best,

Jean Feldman

Head, Policy Office

Division of Institution & Award Support (DIAS)

Office of Budget, Finance and Award Management

National Science Foundation

Notice of Requirement for Electronic Submission of all Administrative Supplements

Notice Number: NOT-OD-20-128

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-128.html

Purpose

This Notice alerts the extramural community of three updates to our administrative supplement submission policies.

·         Effective immediately, NIH will begin accepting administrative supplement applications for multi-project awards electronically. Since the administrative supplement applies to the parent award as a whole, the single-project application form package used for research grants and cooperative agreements will be used for these submissions (e.g., Competition ID= “FORMS-F-ADMINSUPP-RESEARCH.”)

·         Effective July 25, 2020, the streamlined submission method through the eRA Commons will be discontinued and replaced with the option to initiate the administrative supplement application within eRA Commons and leverage technology available in NIH ASSIST to complete submission.

·         Effective July 25, 2020, all supplement applications to existing single and multi-project awards must be submitted electronically through Grants.gov using NIH ASSIST, Grants.gov Workspace, or institutional system-to-system (S2S) solutions.

Background

Administrative supplements are requests made for additional funds during a current project period to meet increased costs that are within the original scope of the approved award but were unforeseen when the new or renewal application or grant progress report for non-competing continuation support was submitted.

Currently, NIH does not require the electronic submission of administrative supplement applications. Requests for administrative supplements can be submitted utilizing a variety of submission methods including streamlined submission through the eRA Commons (subset of standard application information submitted directly to NIH within eRA Commons); electronic submission through Grants.gov using NIH ASSIST, Grants.gov Workspace, or institutional system-to-system (S2S) solutions; or by utilizing paper-based applications.

Paper-based submission poses a challenge to NIH staff when trying to track and capture structured data elements and streamlined submission through eRA Commons does not provide the level of detail captured in a full application through Grants.gov. An increasing number of administrative supplement opportunities have required electronic submission through Grants.gov to address these issues.

Aligning the administrative supplement application process with the business practice used for competing applications also allows us to standardize our application instructions.

Policy Implementation

Effective July 25, 2020, NIH will require recipients to submit all administrative supplement applications, electronically, for both single and multi-project awards.

Application Submission Information

These changes apply to all NIH administrative supplement funding opportunity announcements (FOAs).

NIH will reissue the following administrative supplement parent announcements. Any in-progress applications submitted through Grants.gov using these announcements must be completed by July 24, 2020. Applications submitted on/after July 25, 2020 must use the reissued announcements.

·         PA-18-591 - Administrative Supplements to Existing NIH Grants and Cooperative Agreements (Parent Admin Supp - Clinical Trial Optional)

·         PA-18-592 - Research Supplements to Promote Re-Entry into Biomedical and Behavioral Research Careers (Admin Supp - Clinical Trial Not Allowed)

On July 25, 2020, NIH will also implement changes to the eRA Commons submission method that will improve comprehensive data collection by leveraging technology available in NIH ASSIST. The current streamlined submission method through eRA Commons (subset of standard application information submitted directly to NIH within eRA Commons) will be discontinued and replaced with the option to initiate administrative supplement applications within eRA Commons to take advantage of pre-population and other features and completing the submission in NIH ASSIST. This functionality will be available even if responding to a Notice of Special Interest (NOSI) that indicates “the process for Streamlined Submission using the eRA Commons cannot be used for this initiative.”

If you have any questions, please contact the Office of Sponsored Programs @ ospa@umbc.edu.

Guidance Regarding Change in Status, Including Absence of PD/PI and Other Key Personnel Named in the Notice of Award

Notice Number:  NOT-OD-20-124

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-20-124.html

Purpose

The purpose of this notice is to clarify NIH expectations regarding change in status, including absence of Program Director / Principal Investigator (PD/PI) and other Key Personnel named in the Notice of Award (NoA) of NIH grants, as well as change in recipient institution. NIH expects that funded biomedical and behavioral research occurs within an environment that is safe, healthful, and conducive to high-quality work.

These updates apply to both requests for a change in status as outlined in the NIH GPS 8.1.2.6, “Change in Status, Including Absence of PD/PI and Other Senior/Key Personnel Named in the NoA,” and 8.1.2.7, “Change of Recipient Organization.”

Change in PD/PI and Other Senior/Key Personnel

NIH is modifying section 8.1.2.6 for clarification. The requirements for obtaining prior approval are not changing. See changes to particular sentences in italics:

The recipient is required to submit a prior approval request to the Grants Management Official (GMO) if:

·         There is a significant change in the status of the PD/PI or other Senior/Key Personnel specifically named in the NoA including but not limited to withdrawing from the project entirely, being absent from the project during any continuous period of 3 months or more, or reducing time devoted to the project by 25 percent or more from the level that was approved at the time of initial competing year award (for example, a proposed change from 40 percent effort to 30 percent or less effort or in calendar months a change from 4.8 to 3.6 calendar months). Reductions are cumulative, i.e., the 25% threshold may be reached by two or more successive reductions that total 25% or more. Once agency approval has been given for a significant change in the level of effort, then all subsequent reductions are measured against the approved adjusted level. Selecting Yes in the RPPR constitutes a prior approval request to the agency and the issuance of a subsequent year of funding constitutes agency approval of the request

·         There is a change from a multiple PD/PI model to a single PD/PI model.

·         There is a change from a single PD/PI model to a multiple PD/PI model.

·         There is a change in the number or makeup of the PD/PIs on a multiple PD/PI award.

NIH must approve any alternate arrangement proposed by the recipient, including any replacement of the PD/PI or senior/key personnel named in the NoA, and the addition of any new PD/PIs.

The request for prior approval of any additional or substitute PD/PIs or Senior/Key Personnel named in the NoA, or change from a multiple PD/PI model to a single PD/PI model, must be submitted promptly, and must be accompanied by a strong scientific justification related to the scientific project, including any proposed changes in scope, the biographical sketch of any new individuals proposed and other sources of support, and any budget changes resulting from the proposed change. A new or revised Leadership Plan is required if the request is to change from a single PD/PI model to a multiple PD/PI model, or to change the number or makeup of the PD/PIs on a multiple PD/PI award. The Commons ID must be provided for any new PD/PIs. In addition, because NIH recipients are expected to provide safe and healthful working conditions for their employees and foster work environments conducive to high-quality research, the request for approval should include mention as to whether change(s) in PD/PI or Senior/Key Personnel is related to concerns about safety and/or work environments (e.g. due to concerns about harassment, bullying, retaliation, or hostile working conditions). NIH will in turn be better positioned to enable informed grant-stewardship decisions regarding matters including, but not limited to, substitute personnel and institutional management and oversight.

Change in Recipient Institution

NIH also expects that requests for change in recipient institution, as outlined in 8.1.2.7, should include mention as to whether the change in recipient institution is related to concerns about safety and/or work environments (e.g. due to concerns about harassment, bullying, retaliation, or hostile working conditions) involving the PD/PI. NIH will in turn be better positioned to enable informed grant-stewardship decisions regarding matters including, but not limited to, substitute personnel and institutional management and oversight. The NIH expects both the relinquishing and applicant organizations to disclose whether a Change of Recipient Organization is occurring within the context of an ongoing or recent investigation of misconduct of any kind, including but not limited to professional misconduct or research misconduct.

Therefore, for awards (competing, non-competing and supplements) issued after the publication date of this notice, NIH expects recipients requesting prior approval for change in PI or Senior/Key Personnel named in the NoA, or changes in recipient institution to include mention as to whether these requests are related to concerns about the safety and/or work environments as noted above.

Please refer to the full announcement and the NIH Grants Policy Statement.