Reminder of NIH Requirements for Submission of Financial, Administrative, and Scientific Closeout Reports in a Timely and Accurate Fashion

Notice Number: NOT-OD-09-128

Key Dates
Release Date: August 6, 2009

Issued by
National Institutes of Health (NIH), (http://www.nih.gov)

Other Relevant Notices  

Purpose

This Notice is a reminder that NIH grantees are obligated to provide timely and accurate final closeout reports on the financial, programmatic, and administrative aspects of their grant within 90 days after the project period end date.  This includes ensuring that there are no discrepancies between the final Financial Status Report and the Payment Management System’s Federal Cash Transaction Report.
A summary of the requirements for closeout reports and procedures for submitting the required documents to NIH are provided below.

Policy Reminder:

NIH recipients shall submit within 90 calendar days after the last day of the final budget period a Final Financial Status Report (FSR), a Final Progress Report, and a Final Invention Statement and Certification (as applicable).  It is important to note that unless the Grants Management Officer (GMO) of the respective awarding component approves an extension of this 90-day reporting window in writing, grantees must submit the final reports within the prescribed timeframe.

NIH encourages grantees to submit all documents through the eRA Commons and grantees are required to submit an electronic final FSR through the eRA Commons (see NIH Guide Notice NOT-OD-07-078 for more information on this requirement).  Additionally, all non-financial closeout documents (such as the final progress report and HHS 568 Final Invention Statement and Certification) not submitted through the eRA Commons are required to be submitted to the following address.

NIH Centralized Processing Center
6705 Rockledge Drive
RM 2207, MSC 7987
Bethesda, MD 20892 (for regular or US Postal Service Express mail)
Bethesda, MD 20817 (for other courier/express deliveries only)
Fax: (301) 480-2304
E-mail: DeasCentralized@od.nih.gov

1. The Financial Status Report (FSR) – (Standard Form 269 or 269A, whichever is applicable)

The final FSR must indicate the exact balance of unobligated funds and may not reflect any unliquidated obligations. There must be no discrepancies between the Federal share of net outlays reported on the final FSR and the net disbursements reported on the Payment Management System's (PMS) Federal Cash Transaction Report (SF-272). It is not acceptable to submit an inaccurate FSR in order to meet the reporting deadline and then submit a revised FSR to correct it. FSRs should be on-time and be accurate at the time of submission.  Failure to submit an accurate, on-time FSR with no discrepancies between the PMS’s Federal Cash Transaction Report may result in undisbursed funds which may be de-obligated and therefore unavailable for use.  It is the grantee’s responsibility to reconcile reports submitted to PMS and to the NIH.

NIH's web-based FSR system allows participants to view currently due and late FSRs, as well as to submit FSRs electronically. Registrations to use this system are processed directly through the NIH Commons web site (http://commons.era.nih.gov/). To register or for questions on how to use the FSR module, please contact the eRA Commons Help Desk at:

NIH Commons User Support Branch Help Desk
http://IThelpdesk.nih.gov/era
(866) 504-9552 (Toll Free)
(301) 402-7469 (Voice)
(301) 451-5675 (Fax)
(301) 451-5939 (TTY)
commons@od.nih.gov

2. The Final Invention Statement and Certification (HHS 568)

The grantee must submit an HHS 568 form whether or not the funded project results in any subject inventions, and whether or not inventions were previously reported. The HHS 568 must list all inventions that were conceived or first actually reduced to practice during the course of work under the project, and it must be signed by an authorized institutional official. The completed form should cover the period from the original effective date of support through the date of expiration or termination of the award.

To expedite the process, electronic submission through the eRA Commons is preferred; however, faxes or emails of a hard copy sent to the NIH Centralized Processing Center listed above are also accepted. If there were no inventions, the form should indicate “None.” Copies of the HHS 568 form are available on the Edison website at https://s-edison.info.nih.gov/iEdison/ nihprocs.jsp or at http://grants.nih.gov/grants/forms.htm.

For certain programs (activity codes = C06, R13, R25, S15, Ts, and Fs), the Final Invention Statement and Certification is not currently required. For questions, the grantee should contact NIH awarding Institute or Center and follow their instructions.

When invention reporting is required, the HHS 568 does not relieve the responsible party of the obligation to assure that all inventions are promptly and fully reported directly to the National Institutes of Health, as required by terms of the award. Additional information on invention reporting and related extramural intellectual property policy issues can be obtained from the office below.

Division of Extramural Inventions and Technology Resources (DEITR)
Office of Policy for Extramural Research Administration, OPERA, OER, NIH
6705 Rockledge Drive, MSC 7980
Bethesda, MD 20892-7980
TEL: (301) 435-1986
E-mail: Edison@od.nih.gov

3. The Final Progress Report

The final progress report should be prepared in accordance with requirements in the PHS 2590 instructions and any specific requirements set forth in the terms and conditions of the award.  At a minimum, the report should include a statement of progress made toward the achievement of originally stated aims, a list of significant results (positive or negative), and a list of publications.  Also, describe any data, research materials (such as cell lines, DNA probes, and animal models), protocols, software, or other information resulting from the research that is available to be shared with other investigators and how it may be accessed.  If human subjects were included in the research, the final progress report also should address the following:

If a competitive renewal (Type 2) has been submitted, whether funded or not, the progress report contained in that application may serve in lieu of a separate final progress report. 

Compliance Reminder:

As NIH continues to improve its systems for processing closeout reports and identifying grantee institutions that consistently submit late closeout reports, it is important to understand the significance of noncompliance with these requirements.

Failure to submit timely and accurate final reports may adversely affect future funding to the organization.  Accordingly, NIH may impose sanctions on institutions that fail to correct recurring reporting problems.  Such sanctions may include, but are not limited to, corrective actions, removal of authorities, and/or delay or withholding of further awards to the project or program.

Inquiries

A more detailed discussion of reporting obligations can be found in the NIH Grants Policy Statement discussion on monitoring and reporting, located at http://grants.nih.gov/archive/grants/policy/nihgps_2003/nihgps_part8.htm#_Toc54600141

For more information on the NIH closeout processing center, please contact the center directly at DeasCentralized@od.nih.gov or at (301) 594-6584.  For more information on grants policy and closeout requirements, please visit: http://grants.nih.gov/grants/policy/policy.htm or e-mail GrantsPolicy@mail.nih.gov.


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