Our previous posts in this series described NIGMS research priorities; major research project grants that we support; and overviews of our Institute’s research training, workforce development, and research capacity building programs. In this post, we discuss the notice of award (NOA), project reporting requirements, flexibilities in award management, and matters that require additional NIGMS approval.
How Do I Manage the Post-Award Process?
Once a grant has been awarded, there are post-award requirements principal investigators and institutions must follow to ensure the project remains on track. It can be challenging to keep up with and navigate the post-award policies and procedures. As a starting point, it’s always beneficial to contact your authorized organization representative (AOR) with questions. The AOR is usually in the office of sponsored research or equivalent, and they are listed in a number of places, including the grant application, the NOA, and required progress reports. Check with your institutional officials or sponsored research office to determine the best way to contact them. AORs are experts on your organization’s internal policies and procedures and represent your organization on issues related to the NIH award. Your AOR is also your organization’s designated representative for award issues, including those that require NIH approval (see section below: What Grant-Related Changes Need Approval?).
Where Is Information About a Grant Award Found?
An NOA is issued for every budget period of the grant and is the official document that reflects funding amounts for current and future years, start and end dates, names of your program official (PO) and grants management specialist (GMS), and importantly, the terms and conditions of the specific award. You can find a copy of the document in eRA Commons. You’ll want to read through the document carefully to understand the requirements of the award. Terms and conditions are outlined in sections III (standard terms and conditions) and IV (NIGMS-specific award conditions) and reference requirements and expectations for the award. It’s important to note that initial PO and GMS contacts, as well as recommended future-year funding amounts, are subject to change.
How Is Research Progress Reported?
As an award recipient, you must report on your progress by submitting research performance progress reports (RPPRs). NIGMS program and grants management staff review these reports to assess how well a project is progressing and whether the grantee is being fiscally responsible. Reporting requirements are included in the NOA and in the NIH grants policy statement. There are three different types of RPPRs: annual, interim, and final. The annual RPPR must be submitted shortly before the next budget period start date. If you were awarded an NIGMS training grant, see section IV of the NOA for the applicable due date. RPPRs for multi-year funded grants are due annually on or before the anniversary of the budget/project period start date. An interim or final RPPR must be submitted after the final year of the award to report on project outcomes or findings and a concise version is made available to the public. eRA emails are sent to remind you and your AOR of the type of RPPR that is due and when.
All of the reports must adhere to the NIH RPPR instruction guide [PDF] and must be submitted through eRA Commons. If you need step-by step instructions, the eRA Commons online help guide provides detailed directions on submitting the RPPR. The FAQs also provide answers to commonly asked questions on all topics related to RPPRs.
What Grant-Related Changes Need Approval?
You may be wondering what types of changes to the research plan and budget can be made after the award is issued. For example, can a necessary piece of equipment for the project be purchased without NIGMS prior approval? You may be surprised to learn that the award recipient has flexibility to make some changes within the project and budget in accordance with their own institutional policies and without NIH approval. These flexibilities stem from laws that permit NIH to extend expanded authorities to NIH awards.
For example, without NIGMS approval and in accordance with the NIH grants policy statement, it’s within your institution’s purview to:
- Extend a project period for up to 12 months without additional NIH funds, with some exceptions—known as a first no-cost extension (NCE)
- Carry over unobligated balances from one budget period to the next (unless the NOA says prior approval is required or NIGMS determines that all or some of the unobligated funds are unnecessary to complete the project). It’s important for you to monitor that the grant expenditures are occurring at a reasonable rate. The accrual of excessively large unspent balances must be described in the annual RPPR and, in some cases, can result in a reduction in the next award level.
- Make cost-related changes, including rebudgeting funds for allowable costs, as long as the scope of the research remains the same (this includes the purchase of equipment in relation to the project’s scientific needs)
Certain changes to your project always require NIH approval in advance of the change. These include among others:
- Change of scope—taking an action that changes the scope of the funded project
- Change in principal investigator (PI)/multiple PI status
- Change of recipient organization—transferring the award/project to a new institution
Additional no-cost extensions—exceptional justification requiring prior NIGMS approval for extensions beyond the first NCE- Revisions for an approved data management and sharing plan
- Deviations from the award terms and conditions—undertaking any activities disapproved or restricted as a term of award
- Addition, removal, or transfer of a foreign subaward or foreign site
All prior approval requests must include the AOR’s approval, usually by AOR submission in the prior approval module or via AOR email submission to the assigned NIGMS GMS with a copy to the assigned NIGMS PO.
Both the assigned GMS and PO review prior approval requests; however, only the GMS and/or the grants management officer can approve or deny a request.
What If I Have Additional Questions During the Award Period?
Start with your departmental research administrators and your organization’s AOR. If there are still questions, the AOR can reach out to the assigned NIGMS GMS for guidance. For scientific matters and questions, you may reach out to the PO directly; however, if the discussion results in changes to the project, the AOR and NIGMS GMS must be looped into the discussion to obtain the proper approvals.
How Can I Find More Information?
NIH uses various methods to communicate new and revised policies to applicants and recipients. Here are some ways to stay informed:
- Subscribe to the NIH Guide listserv to get a list of the funding opportunities and the policy notices posted weekly in the NIH Guide
- Sign up for the electronic submission listservs on the subscribe webpage of the NIH electronic research administration website
- Check out the NIH frequently asked questions webpage
- For all things NIGMS, subscribe to our Feedback Loop blog