STREAMLINING THE NIH NONCOMPETING AWARD PROCESS NIH GUIDE, Volume 24, Number 38, October 27, 1995 P.T. 34 Keywords: Grants Administration/Policy+ National Institutes of Health INTRODUCTION On October 1, 1994, the National Institutes of Health (NIH) implemented the Streamlined Noncompeting Award Process (SNAP). Previous notices regarding SNAP appeared in the NIH Guide for Grants and Contracts, Vol. 23, No. 38, October 28, 1994 and Vol. 24, No. 2, January 20, 1995. This notice provides information about the further streamlining of SNAP, and supersedes information contained in previous NIH GUIDE announcements. In the spirit of the Federal government~s reinvention initiatives, the NIH developed a streamlined process for the submission of information necessary to receive a noncompeting award. Before the streamlining, a progress report and four financial documents were required for each grant budget year. This streamlining action eliminated, where nonessential, two of those financial documents that were part of the noncompeting continuation application kit (PHS 2590): a budget for the next budget period and an estimated report of expenditures for the current budget period. The basic principle of SNAP is that at the time of the competing award, the Grants Management Officer negotiates the direct costs for the entire competitive segment, thus eliminating the need to engage in annual direct cost negotiations. As part of that negotiation, NIH staff assures that proposed costs are allowable, allocable, reasonable, and necessary for the project. Since the budget is negotiated for all years of the competitive segment at the time of the initial competing award, annual requirements for financial documentation are streamlined in that only a programmatic progress report, the Federal Cash Transactions Report, and the Financial Status Report are required to enable NIH staff to monitor the scientific and financial aspects of the project. SNAP ELIGIBILITY NIH grant recipients (including those participating in the Federal Demonstration Project) are expected to follow the streamlined noncompeting process for mechanisms routinely covered under expanded authorities, except Program Project Grants (P01s) and Outstanding Investigator Grants (R35s). As published in the NIH Guide for Grants and Contracts, Vol. 23, No. 45, December 23, 1994, NIH routinely applies expanded authorities to Program Project grants (P01s), Minority High School Student Research Apprentice Program awards (S03s), Research Career Awards (K-Series), and all Research Project grants (R-Series), except Phase I Small Business Innovation Research (R43) and Small Business Technology Transfer (R41) awards. Any award excluded from expanded authorities is routinely excluded from SNAP, unless specifically included in SNAP as a term and condition of the award. Individual awards may be excluded from routine inclusion under SNAP (and expanded authorities) based on the following criteria: o Grants that require close project monitoring or technical assistance, e.g., clinical trials, exceptional (high risk) grantees, certain large individual or multi-project grants, or grants with significant unobligated balances. o Grantees that have a consistent pattern of failure to adhere to appropriate reporting or notification deadlines. Any additional activity that has been included under expanded authorities at the discretion of an awarding Institute or Center (e.g., centers, training grants, or cooperative agreements), will be excluded under SNAP, unless inclusion is specifically footnoted as a term and condition of the award. SNAP INSTRUCTIONS The instructions for submitting the streamlined noncompeting application require that the information below be provided at the beginning of the Progress Report Summary (Form Page 5 from PHS 2590 kit, rev. 5/95). These instructions are included in the PHS 2590 (rev. 5/95) under A. Simplified Instructions, page 2. In providing the information, the following guidance applies. o Has there been a change in the other support for key personnel? Specific information is to be provided only if active support has changed. If a previously active grant has terminated and/or if a previously pending grant is now active, the change in support is to be reported. Submission of other support information is not necessary if support is pending or for changes in the level of effort for active support reported previously. Other support information should be submitted only for the principal investigator and for those individuals who are considered by the principal investigator to be key to the project. Key personnel is defined as an individual who contributes in a substantive way to the scientific development or execution of the project, whether or not a salary is requested. Key personnel is defined on page 11 of PHS 398 grant application kit (rev. 5/95). o Will there be, in the next budget period, significant rebudgeting of funds? Significant rebudgeting occurs when expenditures in a single direct cost budget category deviates (increases or decreases) from the categorical commitment level established at the time of the competing award by more than 25 percent of the total amount awarded or $250,000, whichever is less. The basis for determining significant rebudgeting excludes the effects of carryover of prior year unobligated balances, but includes competing or administrative supplements. This implementation redefines significant rebudgeting contained in the current PHS Grants Policy Statement (rev. 4/1/94), Pages 8-1 and 8-7. o Will there be, in the next budget period, a change in the level of effort for key personnel? A significant change in level of effort is defined in Federal regulations as a 25 percent reduction in time devoted to the project. For example, if a key person on the project is expected to reduce his/her effort from 40 percent to 30 percent, which represents a 25 percent reduction in the level of effort, the detailed budget page (Form Page 2) and the budget justification page (Form Page 3) are to be submitted in the noncompeting continuation. This requirement applies regardless of whether or not the key person is compensated from the grant. o Explain any estimated unobligated balance (including prior year carryover) that is greater than 25 percent of the current year~s total budget or more than $250,000. An estimated unobligated balance that meets this criterion is to be reported on the Progress Report Summary page (Form Page 5). An explanation of why there is a significant balance and how it will be spent if carried forward into the next budget period is to be provided. The questions regarding other support and significant rebudgeting and/or change in level of effort must be answered by stating that no change has occurred or is planned. If a change has occurred or is planned, the appropriate form and/or justification is to be submitted in the noncompeting continuation application. Information regarding unobligated balances must be provided when it is anticipated that there will be an unobligated balance (including prior year carryover) of 25 percent of the current year~s total budget or more than $250,000. The Progress Report Summary (Form Page 5) is to be used to provide the requested information, which should be provided before beginning the progress report. The progress report instructions contained in pages 7-9 of the PHS 2590 (rev. 5/95) should be followed for reporting on research progress. Separate progress reports are routinely required for special supplements awarded specifically to support the addition of an individual to the project. The Research Supplement for Underrepresented Minorities and the Research Supplement to Promote the Recruitment of Individuals with Disabilities into Biomedical Research Careers are examples of special supplements requiring separate progress reports. A separate budget for these special supplements is not required unless there is a significant change as discussed above. SNAP PHASE II The second phase of SNAP is a logical extension of the award process and involves the Noncompeting Notice of Grant Award. Beginning October 1, 1995, noncompeting award notices for grants subject to the SNAP will be issued without direct cost categorical breakdowns (e.g., personnel, supplies). Award notices will provide only the total direct and indirect costs awarded for that budget period. For this phase-in year, indirect cost base and rate information will be provided either on the award notice or as an attachment. Although SNAP awards provide no categorical breakdown of direct costs, recipients are required to allocate and account for these costs by category in accordance with applicable cost principles. Future Year Commitments: Remaining future year commitments will be modified to reflect total cost (both direct and indirect) commitments. (See NIH Guide notice "Future Year Commitments on NIH Grant Awards" in this issue.) PRIOR APPROVAL REQUIREMENTS The grant mechanisms included in SNAP are administered under the Expanded Authorities' provisions of OMB Circular A-110, which waives cost related prior approvals. The prior approval authorities retained by PHS will remain in effect under SNAP. However, three indicators of "Change of Scope or Research Objectives" as contained in the PHS Grants Policy Statement on page 8-7 (rev. 4/1/94), require clarification since noncompeting awards under SNAP will not have categorical direct cost breakdowns. a. Initiating patient care activities where none had been approved during the negotiation of a competing award will continue to signify a change in scope and is based on programmatic changes rather than rebudgeting actions. b. Initiating a subcontract that transfers a substantial portion of the work to a third party where none had been approved during negotiation of competing award also remains an indicator of a change in scope and is based on programmatic changes rather than rebudgeting actions. c. Significant rebudgeting continues to be an indicator of change of scope. However the basis on which significant rebudgeting is determined has been redefined. (See above.) INQUIRIES Grantee staff with questions about SNAP should contact the Grants Management Specialist identified on the Notice of Grant Award. .
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