GIM 18
Postaward Administration of National Institutes of Health (NIH) Grants

SUBJECT: Postaward Administration of National Institutes of Health (NIH) Grants

SUPERSEDES: GIM 18, Revised October 23, 2002

RELATED INFORMATION: GIM 12

This notice supersedes Grants Information Memorandum (GIM) 18 dated October 23, 2002 entitled "Postaward Administration of Public Health Service (PHS) Grants." GIM 18 included the revised expanded authorities from the PHS Grants Policy Statement, (December 2003) Rules and regulations of NIH.

Applicants for NIH grants and grantees have historically relied on a variety of sources for information about the grants process and requirements of NIH. While many of these sources were developed and maintained by NIH, the primary source of information for grantees was the PHS Grants Policy Statement. That document was issued by the Office of the Assistant Secretary for Health, an organizational level that has been eliminated as part of the streamlining efforts of the Department of Health and Human Services (HHS). The NIH decision to publish its own policy statement is based on the need to provide its grantees with updated information as well as its desire to enhance its method of communicating about its grants policies and process. Although much of the content of the new NIHGPS may be applicable to grants awarded by other PHS or HHS components, NIH has developed this document for its own purposes.

The NIHGPS is effective for all NIH grants and cooperative agreements (hereafter, "grants") for budget periods beginning on or after December 2003 While the NIHGPS has been reformatted, most of the actual changes to the content of the prior PHS Grants Policy Statement are technical amendments to reflect current requirements rather than substantive changes in policy. An explanation of the major changes from the PHS Grants Policy Statement is included in the NIH Guide for Grants and Contracts - NIH Guide NOT-OD-04-009 announcing the issuance of the NIHGPS. The NIH Guide is published on the NIH Website's Grants Policy and Guidance.

Attachment A, Administrative Agreements, pages II-52 through II-60 from the NIH Grants Policy Statement, contains the rules and regulations for postaward administration including Expanded Authorities for all NIH grants. Please note that significant rebudgeting is defined as occurring "when expenditures in a single direct cost budget category deviate (increase or decrease) from the categorical commitment level established for the budget period by more than 25 percent." For example, if the award budget for total costs is $200,000, NIH prior approval is required for any rebudgeting that would result in an increase or decrease of more than $50,000 in a budget category. (See Attachment A, page 2 for more detail.) When the applicable threshold is reached, the Principal Investigator must consult with the NIH Grants Management Officer, so advising Office of Sponsored Programs, to determine if this constitutes a change of scope and if prior approval by NIH is required. If prior approval is determined to be required, the Principal Investigator must forward a written request through Office of Sponsored Programs for concurrence to the NIH Grants Management Officer.

Under expanded authorities, the University is allowed to authorize extensions without additional funds, to approve carryover of unobligated balances at the end of a budget period, and to waive certain cost related and administrative prior written approvals required by OMB Circular A-21.

The University, at its own risk, is authorized to incur pre-award costs up to 90 days prior to the beginning date of an award, and is willing to assign a budget number in advance within the 90 day period if a request with adequate justification in accordance with GIM 9 is received in Grant and Contract Accounting (GCA) prior to the proposed start date.

The University is allowed to extend, without additional funds, the final budget of a project period on some grants for UP TO ONE YEAR beyond the original expiration date under certain conditions explained in the attachment, provided NIH is notified by the University at least 10 days prior to the expiration date of the project period. In order to implement this feature, the Principal Investigator must write to Office of Sponsored Programs at least 20 days prior to the expiration date. The request should include the length of time being requested and the justification (see conditions in Attachment A). If the justification is appropriate, Office of Sponsored Programs will send an extension notice to Grant and Contract Accounting and also notify NIH of the extension.

The University is required to notify NIH if the PI or other key personnel named in the NGA will withdraw from the project entirely, be absent from the project during any continuous period of three months or more, or change (reduce or increase) his or her time devoted to the project by 25 or more percent from the level that was approved at the time of award (for example, a proposed change from 40 percent effort to 30 percent or less effort). NIH must approve any alternate arrangement, including any replacement PI or other key personnel proposed by the University.

Investigators should be aware that the NIHGPS states, "Even where the grantee is authorized to use expanded authorities, if it is determined, through audit or otherwise, that costs do not meet the tests of allowability, allocability, reasonableness, and consistency, the costs may be disallowed."

Overexpenditures Between Budget Periods

NIH requires overexpenditures, or deficits, at the expiration of a budget period be closely reviewed prior to carryforward to the non-competing (continuation) or competing renewal period. When it is anticipated that preaward activities may result in a deficit, preaward authority in accordance with the requirements in GIM 9, Advance Budget Number assignments, should be obtained for competing renewals and for non-competing continuations, including SNAP (Streamlined Non-Competing Application Process) awards. For non-competing awards, preaward authority should be requested whenever a deficit from the prior period exceeds 5% of the cumulative award. If preaward authority is granted by OSP, the preaward costs may be incurred on the existing budget number and any resulting deficit will be carried forward to the next budget period. As per current procedure, SNAP awards will retain the same budget number for the entire competitive segment.

Where advance authority was not obtained from OSP in accordance with GIM 9 as noted above, GCA will request information from the department and/or Principal Investigator to determine whether the costs in excess of the award for the period are appropriate for the non-competing continuation or competing renewal period (i.e., acceptable preaward activities). Overexpenditures which are not appropriate for the non-competing continuation or competing renewal period must be transferred by the department to an appropriate non-federal funding source. Examples of acceptable preaward activities may include, but are not limited to, the following:

• Participation of personnel proposed for a future period was needed earlier than expected

• 
  Equipment identified in the proposal for purchase in a future period was necessary earlier than anticipated
• 
  Purchase of critical supply items at or near expiration for use during the renewal period
• 
  Purchase of items necessary to maintain continuity of the project in which the resulting deficit is less than 5% of the cumulative award amount prior to renewal.

Deficits resulting from oversight, ineffective budgeting or other cost related conditions would not be considered preaward activities and thus would require transfer to an appropriate non-federal funding source.

Questions may be directed to your Office of Sponsored Programs. Get Specific OSP Contact Information.