Live Wires: No Cost Extension and PI Changes Go Electronic

As of last Thursday, No Cost Extensions requiring a prior approval and requests to change a PD/PI are available to your GCO through the Prior Approval section in eRA Commons.  The electronic option through eRACommons is just that: optional.  You and your GCO can still make your requests the old-fashioned way if computers make you nervous (heck, even NIH says you should contact your awarding institute/center [IC] to determine the best method for making these requests).  How simple is this?  Once you sign in, here’s what you see:

And takes you here:

 

Not sure if you are eligible for a no cost extension (NCE) through prior approval?  Do a quick double-check:

  • You ARE eligible for a NCE through Prior Approval:
    • When an NCE under expanded authority has already been used and the grant is within 90 days of the project end date.
    • When the grantee is not under expanded authority and the grant is within 90 days of the project end date.
    • When the project end date has expired and has not been closed or has not entered unilateral closeout, whichever comes first.

 

  • You are NOT eligible for a NCE through Prior Approval:
    • When an NCE under expanded authority has never been requested and the grant is within 90 days of the project end date. In this case, the NCE will be processed normally through the Extension link in Status.
    • When the grant is closed.
    • When the grant is a fellowship grant.

 

  • What information will you need to provide to your GCO?
    • The NCE request form includes:
      • Request Detail – Here you will be asked such things as the number of months you wish to extend the project end date; the amount of unobligated money still available, etc.
      • Three PDF upload fields: Progress Report, Budget Document, Justification Document

 

RAS is here to help with interpretation if you have any questions!

Appendices 2017: Do Not Pass Go. Do Not Collect $200.

With the major November NIH deadlines about to pass us by, many will turn their attention to their 2017 submissions.  As you pursue your application strategies, chances are you’re considering the use of an appendix to bolster your argument for funding.  Proceed with caution: the appendix rules for 2017 are not what they once were.

 

The only allowable appendix materials in 2017 are:

  • Blank informed consent/assent forms
  • Blank surveys, questionnaires, data collection instruments
  • Funding opportunity announcement-specified items

Clinical trial applications may also include clinical trial protocols and/or investigator’s brochures from Investigational New Drug (IND), as appropriate.

 

Note that the revision of allowable appendix material has significantly reduced inclusion potential.  If you weren’t sure before whether you could submit that manuscript, good news: under the new rules, you definitely cannot!  No manuscripts allowed!

 

This announcement was made via NOT in August (check out the full text of NOT-OD-129). The penalties for submitting out-of-bounds material is withdrawal and non-review.  Ouch.   If you have questions about what this change means, or how it may affect your application, give us a shout and we’ll help you talk through it.

Permission to Buzz the Budget

The stone-written commandments of NIH proposals have long included, “thou shalt request prior approval when requesting more than $500,000 in direct costs (excluding consortium F&A costs) in any one year of an unsolicited proposal.” As an aside: did you know you’re supposed to request that approval no later than 6 weeks before submission

 

Since the inception of this rule in the dark ages of 2002, these requests were required in writing or by telephone.  You now have the option of making the request by webform in a new “Prior Approval Module” through eRA Commons (NOT-17-005).  Of important note: you must request the form to be “opened” by your Program Officer before it will be accessible.  Once it is available, you complete the form and submit. As another aside: the word “option” appears to be used loosely here; it’s along the lines of being volun-told).

 

The logic behind the Prior Approval Module appears to be subsequent management of such requests.  The module allows PIs and GCOs to amend, modify and withdraw previously submitted requests as proposals shape up differently in the days leading to deadlines.  The module will appear between the “ASSIST” and “RPPR” tabs on your login screen:

prior_approval

 

 

If you have not yet contacted your Program Officer for access to the module, you will receive an error message (“We are sorry, you are not authorized to access this function”).  Not sure whether to request the limit stretch, or just not sure what to do next?  Drop us a note and we’ll be happy to help you sort through!

 

 

Do We Have An Accord?

New fringe rates take effect in two weeks’ time (October 1), and it’s worth a reminder that any projects awarded with budgets under the previous rates will be responsible for the application of the new rates.  This may mean some re-budgeting so now may be a good time to do a cost projection with the new rates.  Some projects will feel little to no impact; others (particularly those with a lot of non-faculty research persons) will have significantly higher personnel costs.  You may need to rebudget some of your funds; if this is the case, be sure to check the terms of your award to see whether you will need to request agency permission to do so.

 

If you find yourself with a significant budgetary hardship once you’ve projected your expenses on the new rates, reach out to your GCO for options that may be available to you through the university.

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!

No Such Thing as a Free NCE

In case you missed it, Joe Schumaker wrote a good piece this month aligning requests for no cost extensions with the classic Dickens novel, Oliver Twist.  Here’s your bottom line: there can only be one (yes, that was a Highlander reference riffed from a Dickens reference.  All about the classics today, folks).

 

NIH provides an “expanded authorities” clause in almost all Standard Terms of Award that waives the requirement for prior approval No Cost Extension (NCE), among other actions.  If the text of the award allows, the grantee is permitted one NCE (that is, to extend the final budget period of a grant’s project period by up to 12 months, with no new funds).  This is usually done within 90 days of project end, when the Extension link appears in the “Action” column of the “Status” search results screen. Anything beyond that one request will require permission.

 

As NIH adjusts NCE guidelines to meet the requirements outlined in the Uniform Guidance, they have audibly noticed an increasing trend of people asking for NCEs in the middle of the project period. You can do this, but this is your one shot.  That is: if you get a permitted NCE in the middle of your project period, you won’t see your Extension link at the end of your project period;  you’ve already used your expanded authority, even though you had to obtain permission to do so.  Further, if you choose not to use the entire allowable 12 months (like you ask for, say, a 4 month extension), you can’t ask for the remainder of what’s allowable (8 months, in this case) without permission: it still counts as a second extension.

 

So, Warriors, be careful what you wish for; beyond that, know what you’re wishing for.  If you’re unsure of your best strategy, let us know: we’ll help you talk it out and figure what’s best for you!

 

 

Permission to Land Short

In the season of RPPRs and changing budgets, we thought it might be a nice time to once again mention effort reduction on NIH projects.

 

Remember, if you are reducing the effort of key personnel on a grant, you need the permission of your NIH program officer if the amount of effort reduced is 25% or more.  The amount reduced is cumulative; that is, the 25% threshold may be reached by the reduction of two or more efforts per individual in successive project periods.  To revisit an example, take Dr. Alpha: he devotes 25% effort to a project, or 3.0 person months. If he reduces his effort by more than 25% of 3.0 months (which is 0.75 months), he needs permission to reduce.

 

So, if Dr. Alpha reduces his effort in Year 2 by 20% (0.6 months) to 2.4 months, he does not need to request NIH permission. If he reduces his effort again in Year 3 by 10% (0.24 months), he DOES need special permission at that point, because his effort has been reduced from the last approved level by 28%. This is where the “cumulative” term comes into play: once NIH has approved a reduction, all subsequent reductions are measured at 25% of the MOST RECENT approval (as opposed to consistent measurement against the first-year effort levels, if subsequent changes were made). For further details on the 25% thresholds, be sure to read the Section 8 of the NIH Grants Policy Statement. If you need some guidance on calculating your own thresholds, we’re always happy to help!

25 is the Magic Number

The magic number for NIH seems to be “25%”.  Whether we’re talking about carry forward balances or effort devoted to a project, you have to be under the quarter mark or else have special permission.  Here’s how to determine whether you will need to communicate with your program officer (through your GCO, of course!):   CARRY-FORWARD If you find yourself with unspent funds at the end of a project, you can’t carry those funds forward to the next project period without permission, unless the leftover/unobligated funds equal less than 25%  current year’s total approved budget (including prior-year carryover).  If, for instance, your total approved budget for Year Two is $150,000 and you have monies left over going into Year Three, you must request permission from NIH to keep those funds to spend in addition to your Year Three budget IF you have more than $37,500 left over.  The formula to find your threshold is [Period Total Approved Budget] x [0.25].  If you find yourself with $23,000 at the end of Year Two, you’ll likely not need permission to carry it forward and spend it on top of your approved budget for Year Three.** Keep in mind, however, that if you should find yourself with a balance at the end of Year Three, you must include the Year Two carry-forward in calculating your threshold.  If your approved budget for Year Three is also $150,000, your threshold is calculated as follows:

  • [Period Total Approved Budget + Prior Period Carry-Forward] x [25%]
  • = [$150,000 + $23,000] x [0.25]
  • = [$173,000] x [0.25]
  • = $43,250

If you are carrying funds from Year Three to Year Four in this scenario, and you find yourself with a balance of $43,251, you will need to request permission from NIH to do so, or expect to have your award for Year Four reduced/offset by the unobligated amount.  Note: this means that you will still have the authority to spend at the originally-approved amount in Year Four, but the source of that funding becomes dual: part of your funds for Year Four will come from the left-over funds that remain in your account from Year Three, and NIH will send the remainder in the new period award.  In this example, if the Year Four approved budget was also $150,000, NIH would provide Year Four funds in the amount of [Year Four Approved Budget – Year Three Unobligated Balance], or [$150,000 – $43,251] = $106,749.  This does NOT reduce the Year Four budget to $106,749; rather, NIH expects you to spend at the approved $150,000 level using the unobligated funds from the year before and the new funds to make up the difference.  Had a carry-forward been both requested and approved, NIH would have sent a check for $150,000 and allowed the expenditure of the $43,251 on top of the originally-approved budget.

 

EFFORT REDUCTION

Bear in mind that “25%” is also the threshold for NIH permission for project effort level reductions.  This reduction threshold is seen as cumulative, i.e., the 25% threshold may be reached by the reduction of two or more efforts per individual in successive project periods that total 25% or more.  Let’s say that Dr. Alpha devotes 25% effort to a project, or 3.0 months.  His threshold for effort reduction is 25% of 3.0 months, or 0.75 months.  If Dr. Alpha reduces his effort in Year 2 by 20% (0.6 months) to 2.4 months, he does not need to request NIH permission.  If he reduces his effort again in Year 3 by 10% (0.24 months), he DOES need special permission at that point, because his effort has been reduced from the last approved level by 28%.

Note: once NIH has approved a reduction, all subsequent reductions are measured at 25% of the last approval (as opposed to consistent measurement against the originally-approved effort levels).   For further details on the 25% thresholds, be sure to read the Section 8 of the NIH Grants Policy Statement.  If you need some guidance on calculating your own thresholds, give us a shout!

** Remember, certain programs are routinely excluded from the ability to automatically carry forward, no matter the balance.  These include centers (P50, P60, P30, and others); cooperative agreements (U); Kirschstein-NRSA institutional research training grants (T); non-Fast Track Phase 1 SBIR and STTR awards (R43 and R41); clinical trials (regardless of activity code); and awards to individuals.