New Year, New Rules

The brand spankin’ new NIH Grants Policy Statement (NIHGPS) was released on November 25, 2015.  This document governs all NIH awards, so be sure you’re familiar with the changes! In case you missed it, here is a handy table of the changes that were made since the March 2015 version: Summary of Significant Changes

 

The new NIHGPS is available in a web-based format HERE; it is also available in PDF, but NIH encourages the use of the web document.  These terms and conditions are applicable to any award made on or after October 1, 2015 (despite the November release date).  Questions about the changes?  We’re here to help sort them out!

You Don’t Own Me

Coming or going, the transfer of grant awards raises issues of mechanism and ownership (and territoriality!) for many PIs and administrators.  When considering grant transfers, it is important to keep in mind one central tenet: awards are made to institutions, not to PIs.  Even though the PI applies for the grant and does or directs the research, s/he is doing so on behalf of the institution.  Therefore, should a PI decide to change institutions, s/he must have the permission of the institution to take the grant award along (it is, of course, the prerogative of the institution to keep the project and assign new personnel to the research if it so chooses).  That’s where the relinquishing statement comes in.

 

A relinquishing statement is an official statement relinquishing interests and rights in a research grant; different agencies use different mechanisms for generating these statements.  For NIH, the process is initiated in eRA Commons by a signing official of the institution holding the award.  Other funding agencies who do not use eRA Commons have different mechanisms, so be sure to check for agency-specific guidelines.  NSF, for example, requires that the process be initiated by the PI through FastLane once an agreement has been reached by both the current and future grant holders, and requires the FTR (federal cash transactions report) at the time of the request. For detailed instructions on transferring grants from these two federal agencies, check out the NIH  transfer guide assembled by NIAMS, and section IIB2h of NSF’s PAPPG.

 

Our office has shepherded many a transfer, so feel free to reach out if you have any questions on transfer policy or procedure!

The Very Model of a Modern Major General Conditions Guideline

The NIH announced on February 5, 2015 their guide to NIH-specific implementation of the Office of Management and Budget (OMB)’s Uniform Guidelines (UG), in place since December 26, 2014.  The NIH Interim Grant General Conditions apply to all new and supplemental funding provided by Notices of Award issued on or after December 26, 2014; they contain no surprises if you’ve been keeping up with the road to implementation!  If you need a refresher on how we got here, take a look at some of our older posts, like Super Circular, Super Fun, which highlights some of the new provisions in the UG; and Ch-Ch-Changes, which also has a link to the NIH Administration Timeline.

 

To comb over the NIH Interim Guidelines yourself, the full document can be accessed here.  These will be in effect until an updated NIH Grants Policy Statement is published (which won’t be until after the HHS comment period closes).  NIH has provided a frequently asked questions page regarding the interim guidelines, on which you may be able to find an answer to any general questions you may have.  If your question is more specific than an FAQ page can handle, give us a try!  We’re always happy to help with interpretation and applicability!

 

Update: 03/05/15

Looking for some information on what, exactly, has changed? Check out our handy Uniform Guidance Changes: 2015 page!