# Presentation: 308494

## Office of Grants Administration (OGA):Roles and Responsibilities

**Leslie Hickman**
- Grants Management Specialist

## The NIH Extramural Team

-   **Review**

**Program**

-      **Grants Management**

**Notes:**
.The NIH Extramural Team 

consists of review, program, and grants management segments.  

   The NIH seeks to ensure integrity and accountability in it grants administration processes by 
Relying on system of checks and balances
separation of responsibilities

None of theses entities are responsible for or report to the other.  Although these segments are separate and distinct, but do overlap in small but significant ways.  

## Function of Grants Management

- Complement technical role of Program
- Overall responsibility for monitoring grants process
- Facilitate timely business management actions by grantee
- Ensure timely and appropriate actions by the government

## Grants Management Officer (GMO) Activities

- Evaluate application for administrative content
- Negotiate grant awards
- Provide consultation and technical assistance
- Focal point for receiving and acting upon requests for prior NIH approval
- Involvement in all stages of pre-application and application review

## OGA Responsibilities

- The GMO is the **ONLY** NIH official authorized to obligated NIH to the expenditure of funds or to change funding, duration, or other terms and conditions
- OGA maintains the official grant file for NCI

## Pre-application & Application Review

- Review and comment on FOAs
- Resource for the grantee and Program Director on budgetary and policy matters
- Attend site visits, peer review, and NCAB meetings as necessary

## Post NCAB Review

- Review applications selected for funding for compliance with applicable requirements
- Exception funding

## Competing Applications

**Modular**
- Requests costs in $25,000 increments
- Up to $250,000 Direct Costs (excluding 3rd party F&A)
- No detailed budget information
- No individual salary information

**Categorical**
- Requests costs specific to each category
- Over $250,000 Direct Costs (excluding 3rd party F&A)
- Detailed budget information for each category
- Institutional base salaries required

**Notes:**
Modular:  It is the grantee’s responsibility to determine which costs are allowable or not.
Categorical: The GMS must determine whether each line item is allowable, allocable, and necessary.
Justification:  Helps us determine that.  Helps us understand what the costs will be used for.
Type 2 Cap: For competing continuations, the GMS must evaluate whether or not the budget meets the type 2 cap.  If the budget is over, the grantee will be asked for a reduced budget that meets the cap.

## Preaward Review

- IRB/IACUC Approvals
- Certification of Education for Human Subjects Research for all Key Personnel
- Other Support for Key Personnel
- Requested by the PD
- The PD identifies scientific overlap, OGA identifies budgetary and commitment overlap
- Review requested budget
- Review Financial Status Reports (FSRs)

**Notes:**
Certification of Education for Human Subjects Research is required even if research falls under E4 (or any other exemption)

## Preaward Review (continued)

- Negotiate amount of award based upon current funding plan
- Prepare and document Program and GMO recommendations for concurrence memos
- Compose and track special terms and conditions of award

## Other Support

- NIH requires _complete_ and _up-to-date_ other support information prior to award for all key personnel (except consultants)
- _All _sources of research support (including outside the applicant organization).
- Percent efforts must be listed for each project.
- Grantees must report changes as part of the annual progress report.
**     ****NIH Guide, February 13, 2003**
**    ****	****http://grants.nih.gov/grants/guide/notice-files/NOT-OD-03-029.html**

## Other Support Additional responsibilities if the pending grant will be the fifth or higher funded award for the PI:

- Request clarifying information that lists each of the grants the PI currently receives, the approved effort on each grant as well as the effort on the pending award
- Forward updated information to the NCI Program Official for review
- Send an e-mail to all relevant Program staff to organize a discussion of the grants currently funded by NIH

## Other SupportAdditional responsibilities (continued):

- If it is determined that additional information is needed, request a commitment management plan for the PI
- Forward the commitment plan to all relevant Program and Grants Management staff for review and approval
- Add term to the award requiring compliance with the commitment plan as proposed
- Update the NCI grant file for each grant with a copy of the approved commitment plan

**Notes:**
Current funding constraints have brought a heightened awareness to the review of other sources of support, particularly in cases where individual PIs receive multiple grants from the NIH.

## The Electronic Grant File

- The official grant file resides in Egrants
- OGA is in the process of destroying paper files.
- Egrants is used by OGA to electronically document ***all*** aspects of the grant
- All grantee requests received via paper copy are uploaded into Egrants
- Program’s ‘shadow’ files are unnecessary

## OGA’s Electronic Award Process

- Application received and reviewed electronically
- Excel spreadsheet for budget work-up
- GMS Document Control Sheet (Greensheet)
- Award prepared in IMPAC II (import budget and terms)
- NGA issued electronically to grantee

## Slide 16

## Document Control Sheet (Greensheets)

- Electronic Greensheets document the complete review of the application.
- Completed by program directors and grants management specialists
- Includes questions about human/animal subjects, funding plan, foreign involvement, model and data sharing, other support etc...
- Program greensheet needed before specialist greensheet
- Special issues or concerns should be documented in detail
- Additional documents or correspondence may be attached to the greensheet

## Slide 18

## The Notice of Grant Award:NGA OverviewTerms of Award

## Notice of Grant Award (NGA)

- Identifies grantee, project, Principal Investigator
- Indicates funding level
- Indicates period of support
- Sets forth Terms and Conditions
- Provides NIH Contact Information

- LEGALLY BINDING DOCUMENT

## Terms of AwardThe following terms are automatically incorporated into every award:

- Applicable laws and regulations-including 45 CFR Part 74 or 45 CFR Part 92 as appropriate
- Restrictions on the expenditure of federal funds included in appropriations acts
- Reference to the NIH Grants Policy Statement

## Terms of AwardAdditional terms and conditions may be added to the award to:

- Convey general information
- Include IC specific information or requirements
- Place restrictions on the award

## Terms of Award  Terms addressing the following information are added by the specialist to every NCI award:

- NCI Grants Management Specialist and Program Director contact information
- Customer service feedback website
- PubMed Central (PMC) for original research publications resulting from support from NIH

## Terms of Award

- A grantee indicates acceptance of an NIH award and its associated terms and conditions by drawing or requesting funds from the designated HHS payment system or office.
- NIH Grants Policy Statement, December 2003
- http://grants2.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part5.htm

**Notes:**
2 paragraph on the first page of the NGA

- Reviewing Non-Competing Continuation Progress Reports

## Continuing Support

- Grant awards generally for a three, four or five year project period
- Continuing support provided on annual basis subject to the appropriation of funds by Congress
- Support subject to acceptable scientific progress by the PI
- Funds for each future budget period are requested on the non-competing continuation progress report.

## Non-Competing Continuation Progress Reports

- Due 60 days prior to anniversary date (unless E-SNAP:  Due 45 days prior to anniversary date)
- Progress Reports are received centrally & scanned into IMPACII.
- Specialist reviews Progress Report electronically (E-grants)
- Verifies human/animal subjects assurances and IRB/IACUC approvals
- Reviews changes in updated Other Support
- Resolves budgetary issues (carryover requests, restricted funds, financial status reports, etc...)
- Completes greensheet
- Terms of award
- Issue NGA

## Streamlined Non-Competing Application Procedures (SNAP)

- Total Committed Costs are the basis for the award
- Modified financial reporting – FSR only due at the end of the competitive segment
- Three questions in the non-competing progress report

**Notes:**
3 Questions:  The GMS pays particular attention to the answer of the third SNAP question...about the unobligated balance and whether or not it is above 25%.  May prompt the GMS to restructure the award.

## Streamlined Non-Competing Application Procedures

- SNAP Questions:
- Change in the other support of key personnel?
- Significant change in the level of effort for key personnel?
- Estimated unobligated balance greater than 25% of current year’s total budget?

## Traditional/Non-SNAP  Applications

- Submit complete non-competing progress report (PHS 2590)
- Detailed budget and updated other support
- Address unobligated balance greater than 25%
- Total committed costs are the basis for the award
- Annual Financial Status Reports

## OGA Post Award Responsibilities:

**Follow up on restrictive terms of award.**
**Involved in audit resolutions**
**Misconduct concerns**
**Prior approval requests...**

## Responding to Prior Approval Requests

- The Office of Grants Administration serves as the focal point for receiving and responding to all correspondence from the grantees related to business management activities.

##  Activities Requiring Prior Approval 

- No-Cost Extensions beyond the first extension
- Change in Principal Investigator
- Pre-Award costs of more than 90 days
- Addition of a foreign component
- Change in scope or research objectives
- Significant reduction in effort by PI or other key personnel named in NGA

## Prior Approval Requests

**All requests for prior approval must be:**
- Submitted in writing (e-mails are acceptable)
- Submitted to the awarding IC’s Grants Management Specialist no later than 30 days before the proposed change
- Signed by an institutional business official
- Approved by program and grants management staff
**	**

## Responding to Prior Approval Requests

- Official response to grantee requests must by sent by the OGA
- Letters of denial must by signed by the Chief Grants Management Officer
- The official grant file resides in Egrants

## How can you help?

- Send all correspondence to OGA
- Request other support from grantees
- Complete the PD greensheet in a timely manner (by 1st of the month)
- Forward all requests to appropriate offices
- OHRP/OLAW for negotiation of human/animal assurances
- Fogarty for foreign involvement
- Immediately report to DEA and OGA any allegation of misconduct (either fiscal or scientific). Make no contact with grantee/PI. NCI should meet & discuss the issue.

## Helpful Websites

- NIH Grants Policy Statement (Rev. 12/03) _[http://grants.nih.gov/grants/policy/nihgps_2001/index.htm](http://grants.nih.gov/grants/policy/nihgps_2001/index.htm)_
- Human Subjects (OHRP)  _[http://www.hhs.gov/ohrp/](http://www.hhs.gov/ohrp/)_
- Animal Subjects (OLAW) _[http://grants.nih.gov/grants/olaw/olaw.htm](http://grants.nih.gov/grants/olaw/olaw.htm)_
- OER _[http://grants.nih.gov/grants/oer.htm](http://grants.nih.gov/grants/oer.htm)_
- NCI Workbench _[https://i2e.nci.nih.gov/workbench/WorkbenchView](https://i2e.nci.nih.gov/workbench/WorkbenchView)_
- Office of Grant Administration _[http://www3.cancer.gov/admin/gab/index.htm](http://www3.cancer.gov/admin/gab/index.htm)_
- EFDB Intranet _[http://camp.nci.nih.gov/admin/oem/efdb/](http://camp.nci.nih.gov/admin/oem/efdb/)_
- NCI Grants Process Book – Located on NCI’s Office of Grants Administration webpage*  *_*[http://www3.cancer.gov/admin/gab/index.htm](http://www3.cancer.gov/admin/gab/index.htm)*_
- Electronic Submission of Grant Applications Homepage _[http://era.nih.gov/ElectronicReceipt/index.htm](http://era.nih.gov/ElectronicReceipt/index.htm)_
- NCI Grants Process Book (Located on NCI’s Office of Grants Administration webpage)  _[http://www3.cancer.gov/admin/gab/index.htm](http://www3.cancer.gov/admin/gab/index.htm)_