Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

Inspector General 

May 2004 

OEI-01-03-00021 

NIH GRANTS MANAGEMENT: 

LATE CLOSEOUTS 
Office of Inspector General

http://oig.hhs.gov 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, 

as amended, is to protect the integrity of the Department of Health and Human Services 

(HHS) programs, as well as the health and welfare of beneficiaries served by those 

programs. This statutory mission is carried out through a nationwide network of audits, 

investigations, and inspections conducted by the following operating components: 

Office of Audit Services 

The OIG's Office of Audit Services (OAS) provides all auditing services for HHS, either by 

conducting audits with its own audit resources or by overseeing audit work done by others. 

Audits examine the performance of HHS programs and/or its grantees and contractors 

in carrying out their respective responsibilities and are intended to provide independent 

assessments of HHS programs and operations in order to reduce waste, abuse, and 

mismanagement and to promote economy and efficiency throughout the department. 

Office of Evaluation and Inspections 

The OIG's Office of Evaluation and Inspections (OEI) conducts short-ter m management 

and program evaluations (called inspections) that focus on issues of concern to the 

department, the Congress, and the public. The findings and recommendations contained 

in the inspections reports generate rapid, accurate, and up-to-date information on the 

efficiency, vulnerability, and effectiveness of departmental programs. 

Office of Investigations 

The OIG's Office of Investigations (OI) conducts criminal, civil, and administrative 

investigations of allegations of wrongdoing in HHS programs or to HHS beneficiaries 

and of unjust enrichment by providers. The investigative efforts of OI lead to criminal 

convictions, administrative sanctions, or civil monetary penalties. The OI also oversees 

state Medicaid fraud control units, which investigate and prosecute fraud and patient 

abuse in the Medicaid program. 

Office of Counsel to the Inspector General 

The Office of Counsel to the Inspector General (OCIG) provides general legal services to 

OIG, rendering advice and opinions on HHS programs and operations and providing all 

legal support in OIG's internal operations. The OCIG imposes program exclusions and 

civil monetary penalties on health care providers and litigates those actions within the 

department. The OCIG also represents OIG in the global settlement of cases arising 

under the Civil False Claims Act, develops and monitors corporate integrity agreements, 

develops model compliance plans, renders advisory opinions on OIG sanctions to the 

health care community, and issues fraud alerts and other industry guidance. 
� ABSTRACT

Grants management is a priority area for both the Secretary of 

Health and Human Services and the Office of Inspector General. 

In fiscal year 2002, the National Institutes of Health (NIH) 

awarded $19 billion to support 49,000 extramural grants to 

researchers affiliated with more than 2,800 universities, 

hospitals, and other research facilities. When a grant is 

terminated, Federal regulations require the grantee to submit, 

within 90 days, a final financial status report, scientific progress 

report, and invention statement. This grant closeout process is 

critical because it is the final point of accountability for the 

grantee. NIH staff must review and approve these documents in 

order to close out the grant. We have defined, in consultation 

with NIH, an on-time closeout as one that occurs within 150 

days after the grant has been terminated. In August 2002, NIH 

implemented a new computer system to monitor closeouts, 

referred to as the NIH closeout module. 

Based on our analysis of data in the NIH closeout module, we 

found that 88 percent (8,941) of all grants in the module were 

closed out late. The primary cause of late closeouts is grantees 

submitting closeout documents late. Tracking down these late 

closeout documents requires significant time and effort for NIH 

staff. NIH experiences several challenges in taking corrective 

actions against grantees for submitting late closeout documents. 

While the closeout module is a promising tool to help NIH 

monitor closeouts, it has some limitations. To address late 

closeouts we recommend that NIH (1) develop an automated 

reminder system to alert grantees about upcoming due dates for 

closeout documents, (2) facilitate the electronic submission of all 

closeout documents, (3) enhance the closeout module’s 

capabilities, and (4) address late closeouts more systematically 

by focusing on grantee institutions. NIH concurred with our 

recommendations. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS i 
� EXECUTIVE SUMMARY

OBJECTIVE 

To determine the extent to which the National Institutes of Health 

closes out grants on time. 

BACKGROUND 

The National Institutes of Health (NIH) is the largest Federal funder 

of health research and development. In fiscal year 2002, NIH 

awarded $19 billion to support 49,000 extramural grants to 

researchers affiliated with more than 2,800 universities, hospitals, 

and other research facilities. Extramural grants fund scientists and 

organizations outside the agency. NIH awards grants through 24 

distinct institutes and centers (institutes) that are responsible for the 

day-to-day management and oversight of their grants. 

Grants management is a priority area for both the Secretary of 

Health and Human Services and the Office of Inspector General. 

Given that grant closeouts are the final point of accountability for the 

grantee, their timeliness is an important aspect of grants 

management at NIH. When a grant is terminated, Federal 

regulations require the grantee to submit, within 90 days, a final 

financial status report, scientific progress report, and invention 

statement (45 CFR § 74.70-73). The financial status report confirms 

the final accounting of grant funds. At this time, any unobligated 

funds are released. The progress report documents the course and 

results of the research. Finally, the invention statement confirms if 

any inventions were developed under the grant. 

We have defined an on-time closeout, in consultation with NIH, as one 

that occurs within 150 days of the end of the project period. We have 

allowed 60 calendar days for NIH staff to review and approve the 

closeout documents submitted by grantees, in addition to the 90 days 

allowed by Federal regulations for grantees to submit their closeout 

documents. 

In August 2002, NIH implemented a new computer system to monitor 

closeouts, referred to as the NIH closeout module. The purpose of the 

closeout module is to help NIH staff closeout grants on time and, 

when necessary, follow up with grantees to obtain late documents. 

This new module provides an opportunity to document late closeouts 

and their causes. At the time of our review, the module was in use for 

only about 8 months, and institutes used it to varying extents. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS ii 
EXECUTIVE SUMMARY 

Therefore, we cannot make any conclusions about the entire 

population of closeouts based on that data. This limitation applies to 

all data analysis based on the closeout module. 

This inspection is primarily based on an analysis of all data in the 

NIH closeout module, a survey of grantee institutions, and interviews 

with NIH staff. 

This report is one of two that resulted from our inquiry. Our 

companion report, NIH Grants Management: Late Awards (OEI-01-

03-00020), applies a similar methodology to determine the extent to 

which NIH awards noncompeting continuation grants on time. 

FINDINGS 

Eighty-eight percent of all grants in the NIH closeout module were 

closed out late. As of April 2003, the NIH closeout module contained 

10,122 grants, of which 8,941 were closed out late. This includes 

3,118 grants that were closed out after 150 days, and 5,823 grants 

that were still pending after 150 days passed. Fifty grantee 

institutions accounted for almost half of these late closeouts. 

Research project grants, which are one of 10 funding categories, 

accounted for 79 percent of these late closeouts. Late closeouts 

appeared to be common across all funding mechanisms, years, and 

institutes. 

Grantees submitting closeout documents late is the primary 

cause for late closeouts. Based on data in the closeout module, 

grantees submitted final financial status reports late for 49 percent of 

the grants. Grantees submitted final progress reports late for 37 

percent of the grants. And grantees submitted at least 31 percent of 

final invention statements late. NIH does not remind grantees about 

upcoming due dates for closeout documents as the due date 

approaches. However, NIH does remind grantees about their 

closeouts at the time they receive the final year of funding. 

Tracking down missing closeout documents requires significant 

time and effort for institute staff. As late closeouts accumulate, 

institute staff reported to us that they find it difficult to address the 

backlog. Closeouts that are several years old are especially difficult, 

because principal investigators (the scientists who lead the research) 

may have moved on to other institutions and records may not be 

readily available. In order to obtain closeout documents, staff must 

follow up, often multiple times, with grantees. To address this 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS iii 
EXECUTIVE SUMMARY 

workload, several institutes have hired staff and/or contractors that 

are dedicated solely to addressing closeouts. 

NIH experiences challenges in taking corrective actions against 

grantees for submitting closeout documents late. Institute staff 

indicated that they rarely resort to withholding future funding from 

an institution due to late closeouts, because it is too severe a penalty 

and slows down future research. And in many cases, the option of 

withholding future funding is not possible, as the principal 

investigator is no longer conducting NIH research. Twelve percent of 

grantee institutions indicated that NIH had withheld future funding 

from their institution due to late submission of closeout documents. 

And yet, 85 percent of grantee institutions indicated on our survey 

that they had submitted at least one set of closeout documents late in 

the past 3 years. 

While the closeout module is promising, it has some limitations. 

The current closeout module does not automatically include all grants 

eligible for closeout. Institute staff manually enter grants ready for 

closeout into the module; therefore, completeness is dependent on the 

staff updating the system. (Manual entry is necessary in order to 

verify the grant is ready for closeout.) Even for those institutes that 

have entered information, it is uncertain how diligent they are at 

keeping the information up to date. Many records contain missing 

information, which raises questions about whether the information 

was not submitted by the grantee or whether the institute failed to 

enter the information in the module. 

RECOMMENDATIONS 

NIH is taking several important steps toward addressing late 

closeouts, especially in developing the closeout module and planning 

to manage the closeout function from a central office. We encourage 

NIH to continue these efforts. We also recommend NIH: 

o Develop an automated reminder system for grantees to alert 

them of upcoming closeouts 

o Facilitate the electronic submission of all closeout 

documents 

o Enhance the closeout module’s capabilities by ensuring that 

all the information is entered into the module 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS iv 
EXECUTIVE SUMMARY 

o Address late closeouts more systematically by focusing on 

grantee institutions 

Agency Comments 

NIH reveiwed a draft of this report and concurred with our 

recommendations. In its comments, NIH indicated additional steps that 

it is planning to address these issues. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS v 
� TABLE OF CONTENTS

ABSTRACT ................................ ................................ . i

EXECUTIVE SUMMARY ................................ ................ ii

INTRODUCTION ................................ ......................... 1

FINDINGS ................................ ................................ . 7

Eighty-eight percent of grants were closed out late ................. 7

Grantees submit late closeout documents .......................... 11

Tracking down missing closeout documents........................ 13

NIH experiences challenges in taking actions...................... 14

Limitations of the closeout module ................................ . 15

RECOMMENDATIONS ................................ ................. 16

APPENDICES ................................ ............................ 20

Methodology................................ ......................... 20

Confidence intervals ................................ ................ 25

Late closeouts by NIH institute ................................ .... 26

Agency comments ................................ ................... 27

ACKNOWLEDGMENTS ................................ ................. 31

END NOTES ................................ .............................. 32
� INTRODUCTION

OBJECTIVE 

To determine the extent to which the National Institutes of Health 

closes out grants on time. 

BACKGROUND 

The National Institutes of Health (NIH) is the largest Federal funder 

of health research and development. NIH grants support basic and 

clinical research, research centers, scientific training and fellowships, 

and construction projects. 

Recent increases in appropriations have allowed NIH to significantly 

increase its grant-making capacity over the past 5 years. In fiscal 

year (FY) 2003, NIH received $27 billion in total funding, compared to 

$13.6 billion in FY 1998. The President’s proposed budget for FY 

2004 requests $28 billion for NIH. 

About 80 to 85 percent of NIH’s budget supports extramural grants. 

Extramural grants fund scientists and organizations outside the agency. 

In FY 2002, NIH’s total budget was $23.2 billion, of which NIH awarded 

$19 billion in extramural grants. NIH awarded $16.8 billion to support 

43,520 extramural research grants; the remaining $2.2 billion went to 

support 6,196 other extramural grants, such as training and fellowship 

grants. Combined, these funds supported about 49,700 extramural 

grants to researchers affiliated with more than 2,800 universities, 

hospitals, and other research facilities. 

Grants Administration 

Grants management and oversight are critical to ensure that Federal 

funds are used properly. Grants management is a priority area for 

both the Secretary of Health and Human Services and the Office of 

Inspector General, and is among the top management challenges 

identified by the Office of Inspector General for FY 2003.1 As the 

largest funder of health research, NIH must have appropriate policies 

and procedures in place to effectively and efficiently manage its 

grants. The recent increases in NIH funding make it particularly 

important to ensure that NIH has the proper infrastructure to handle 

its increased grant workload. 

The general requirements for grants management at NIH are set 

forth by the Office of Management and Budget and codified in 

regulation by the Department of Health and Human Services.2 These 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 1 
INTRODUCTION INTRODUCTION 

regulations establish requirements for the financial and 

administrative management of each award. 

Additional requirements are provided in the NIH Guide for Grants 

and Contracts, the NIH Grants Policy Statement, and the NIH 

Manual. The NIH Guide for Grants and Contracts is the official 

publication of NIH policies, procedures, and availability of funds. The 

NIH Grants Policy Statement provides a general overview of the 

grant application and review process, including terms and conditions 

for NIH grant awards. (NIH can establish other terms for particular 

institutions.) It emphasizes the importance of good grants 

management by stating, “NIH, as a Federal grantor agency, is 

responsible to Congress and the U.S. taxpayer for carrying out its 

mission in a manner that not only facilitates research but also does so 

cost effectively and in compliance with applicable rules and 

regulations.”3 The NIH Manual contains NIH policies regarding 

internal operations, including requirements for the awarding and 

oversight of extramural grants. 

NIH’s Office of Extramural Research is central to the development 

and maintenance of agency policies regarding extramural grants. It 

also develops program guidelines and information systems related to 

extramural research grants administration. 

NIH awards grants through 24 distinct institutes and centers 

(hereafter referred to as institutes) that are responsible for the day-today management and oversight of their grants.4 Each institute has 

its own grants management office to handle administrative functions 

and to conduct ongoing monitoring of its grants. Grants management 

specialists in these offices are primarily responsible for reviewing 

applications for administrative content and compliance with key laws 

and regulations, reviewing all correspondence and reports from 

grantees, and providing technical assistance to grantees as needed 

throughout the grant process. A chief grants management officer 

oversees the grant specialists. Each institute also has its own 

program office. Program officers establish scientific program goals 

and objectives, which serve as a guide for funding decisions, and 

monitor scientific issues that arise throughout the course of the grant. 

Typically, NIH awards grants with project periods that span several 

years. The project period is the total time for which NIH agrees to 

support the project. NIH divides a multi-year project period into 

budget periods, usually 12-month increments. The budget period may 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 2 
INTRODUCTION 

start at any point during the year. Grants management staff assign 

project periods and budget periods for each grant. 

Grant Closeouts 

Grant closeouts are the final point of accountability for the grantee. 

Failure to close out grants can have negative consequences for NIH as 

well as the grantees. For NIH staff, the consequence of late closeouts 

is that they need to spend significant time and effort following up 

with grantees to obtain late closeout documents. As for the grantees, 

the consequence of late closeouts is that future funding could be in 

jeopardy if NIH chooses to take enforcement actions. 

The closeout process occurs when the grant project period ends or 

when a grant transfers to another institution. At such time, Federal 

regulations require grantees to submit a closeout packet that consists 

of a final financial status report, scientific progress report, and 

invention statement. The financial status report confirms the final 

accounting of grant funds. At this time, any unobligated funds are 

released. The progress report documents the course and results of the 

research. Finally, the invention statement confirms if any inventions 

were developed under the grant. 

Federal regulations require grantees to submit a closeout packet no 

later than 90 calendar days following the termination of a grant.5 

After 150 days, the NIH Manual states that sanctions may be 

imposed.6 

The principal investigator, the scientist who is responsible for the 

direction and conduct of the research, and the grantee institution, the 

organization where the principal investigator is affiliated, are both 

responsible for submitting closeout documents. Typically, the 

principal investigator completes and submits the progress report and 

the invention statement. The grantee institution’s accounting 

department typically submits the financial status report. 

Once the institute receives the closeout documents, the appropriate 

institute staff review and approve the documents. The program 

officer is responsible for reviewing and approving the final scientific 

progress report and the grants management specialist ensures that 

all documents are complete. 

We have defined, in consultation with NIH, an on-time closeout as one 

that occurs within 150 days of the end of the project period. We have 

allowed 60 calendar days for NIH staff to review and approve the 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 3 
INTRODUCTION 

documents submitted by the grantees, in addition to the 90 days 

allowed by Federal regulations for grantees to submit their closeout 

documents. 

Prior Work 

Prior work by the Office of Inspector General (OIG) and others has 

found late closeouts to be a problem for NIH. The OIG reported in its 

Independent Audit Report for FY 2002 that NIH had about 15,283 

grants that were eligible for closeout but had not been closed as of 

September 30, 2002.7 A 1998 General Accounting Office report found 

that 85 percent (628 of 736) of grants at one institute were delinquent 

in providing the complete closeout packages. 8 Data from the National 

Cancer Institute, which has its own system to monitor closeouts, show 

that in FY 2000 and FY 2001 nearly 100 percent of grantees did not 

submit required documentation for closeouts within 90 days.9 

NIH Closeout Module 

In August 2002, NIH implemented a new computer program to 

monitor closeouts, referred to as the NIH closeout module. The 

purpose of the closeout module is to help NIH staff closeout grants on 

time and, when necessary, follow up with grantees to obtain late 

documents. This new module provides an opportunity to document 

late closeouts and their causes. The module pulls information from 

the Information for Management, Planning, Analysis and 

Coordination (IMPAC II) database and, based on this information, 

institutes can enter grants into the module that are ready for 

closeout. Once a grant is in the module, the institute staff can readily 

determine which closeout documents are missing and automatically 

generate emails to the grantee institution requesting the missing 

information. 

METHODOLOGY 

We based our analysis of late closeouts on five sources of data. For a 

detailed description of our methodology and confidence intervals, see 

Appendices A and B. 

First, we analyzed all 10,130 grants in NIH’s closeout module as of 

April 2003. The closeout module is a computer system implemented 

in August 2002 that allows the institutes to monitor grants that are 

ready for closeout. We eliminated 8 grants from our analysis because 

of missing information or apparent data entry errors. The revised 

dataset had a total of 10,122 records. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 4 
INTRODUCT ION 

Second, we obtained computer printouts from the closeout module for 

a stratified sample of 300 grants that were closed out late (at least 

150 days after the project end date) or were still open at least 150 

days after the project end date. We limited our population to three of 

the largest institutes: the National Heart, Lung, and Blood Institute, 

the National Institute of Allergy and Infectious Diseases, and the 

National Institute of General Medical Sciences. We excluded the 

largest institute, the National Cancer Institute, because it already 

has an active monitoring system in place to identify late closeouts and 

their causes. We stratified our sample by institute. We randomly 

selected 100 late closeouts from the National Heart, Lung, and Blood 

Institute (N=522), the National Institute of Allergy and Infectious 

Diseases (N=784), and the National Institute of General Medical 

Sciences (N=254). 

Third, we requested the specific operating procedures related to 

closeouts for all 24 institutes with grant-making authority. 

Fourth, we selected a simple random sample of 135 grantee 

institutions from the 375 locations that received 10 or more research 

grants from NIH in FY 2002. We received 111 replies to our survey, 

for a response rate of 82 percent. 

Finally, we interviewed grants management staff at the National 

Heart, Lung, and Blood Institute; the National Institute of Allergy 

and Infectious Diseases; and the National Institute of General 

Medical Sciences, as well as staff in the Office of Extramural 

Research. 

Data Limitations 

In order for a grant to be captured in the closeout module, institute 

staff must manually enter the grant into the module. Because the 

module depends on someone to enter the grants, it is unlikely that the 

module contains all grants ready for closeout. This is further 

complicated by the fact that at the time of our review, the module was 

in use for only about 8 months, and institutes used it to varying 

extents. For example, some institutes have entered closeouts from 

the past several years, whereas other institutes have only entered the 

most recent closeouts. Therefore, we cannot make any conclusions 

about the entire population of closeouts based on that data. This 

limitation applies to all data analysis based on the closeout module. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 5 
INTRODUCTION INTRODUCTION 

Standards

We conducted this inspection in accordance with the Quality 

Standards for Inspections issued by the President’s Council on 

Integrity and Efficiency.

A COMPANION REPORT 

This report is one of two that resulted from our inquiry. Our companion 

report, NIH Grants Management: Late Awards (OEI-01-03-00020), 

applies a similar methodology to determine the extent to which NIH 

awards noncompeting continuation (type 5) grants on time. A late 

noncompeting continuation award results in a situation in which NIH 

has not issued funding for the next budget period until after the end of 

the previous budget. This causes a gap in funding. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 6 
� FINDINGS

As of April 2003, the NIH closeout 

Eighty-eight percent of all the awards in the NIH module contained 10,122 closeouts, 

closeout module were closed out late. of which 8,941 were closed out late. 

This includes 3,118 grants that 

were closed out after 150 days and 5,823 grants that were still pending, 

but 150 days had already passed. 

The late closeouts in the module were at least 2 years late. Threequarters of the late closeouts were at least 1 year late. Almost half were 

3 years or more late. (See Table 1.) These are conservative estimates 

because 65 percent of the late closeouts remain open, thus, they become 

even later over time. 

Extent of Lateness 

Number of 

Late 

Closeouts 

Percent of All 

Late 

Closeouts* 

151 days to < 1 year 2,374 27% 

1 year to < 2 years 1,087 12% 

2 years to < 3 years 1,483 17% 

3 years to < 4 years 1,421 16% 

4 years to < 5 years 1,183 13% 

5 years and above 1,393 16% 

Overall Total 8,941 100% 

* Numbers do not equal a 100% due to rounding. 

Table 1. Closeouts By Extent of Lateness 

Source: OIG analysis of data from NIH's Closeout Module, 2003 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 7 
FINDINGS 

Three percent of the grantee institutions in the module accounted for 

45 percent of all the late closeouts in the module. There were 1,721 

grantee institutions in the module, yet 50 of these grantee institutions 

represent 4,018 (45 percent) of late closeouts in the module. These 50 

grantee institutions also represent 45 percent of all grants in the 

closeout module. The proportion of late closeouts for those 50 grantee 

institutions ranged from 70 to 96 percent. Thirteen of those 50 

grantee institutions had at least 100 late closeouts. Given that some 

grantee institutions are very large and receive thousands of grants 

from NIH each year, it is not surprising that a small number of large 

grantees accounted for almost half of the late closeouts. These large 

grantees had the largest absolute number of late closeouts, but this 

does not necessarily indicate that they had a greater proportion of 

late closeouts than other grantees. 

Late closeouts were common across funding mechanisms in the 

module. The closeout module included 73 types of funding 

mechanisms, rolled up into 10 categories ranging from research 

project grants (R) to cooperative agreements (U). The proportion of 

late closeouts ranged from 46 percent to 100 percent across the 10 

categories of funding mechanisms. Research project grants (R), which 

8 

Category of Grant Mechanisms 

Number of 

Closeouts in the 

Module 

Number of Late 

Closeouts in the 

Module 

Percent of Late 

Closeouts in the 

Module 

Research Projects (R) 7,974 7,242 91% 

Research Career (K) 701 658 94% 

Fellowship (F) 310 245 79% 

Research Programs and Centers (P) 274 239 87% 

Research-Related Programs (S) 447 205 46% 

Cooperative Agreements (U) 165 155 94% 

Training Programs (T) 103 96 93% 

Resource (G) 85 58 68% 

Research Construction (C) 62 42 68% 

General Clinical Research Center (M) 1 1 100% 

Overall Total 10,122 8,941 88% 

Table 2. 

Source: OIG analysis of data from NIH's Closeout Module, 2003 

Late Closeouts by Grant Mechanism 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 
FINDINGS 

are the most common type of grant mechanism used by NIH, 

accounted for 79 percent of all grants in the closeout module. Of those 

research grants, 91 percent were closed out late. (See Table 2 on the 

previous page.) 

Within the module, late closeouts appeared to be a problem across all 

years. NIH began using the closeout module starting in August 2002. 

At that time, some institutes entered the most current grants into the 

module, while others entered grants that had been pending closeout 

for several years, as far back as 1994. Considering these varying 

approaches to entering data into the closeout module, and recognizing 

that some institutes have entered all closeouts and others have 

entered more recent closeouts, it is difficult to look at the trend of 

closeouts across the years. Still, for the more recent years of 1999 to 

2002, over 1,000 grants were closed out late per year. In 2002, the 

year in which the closeout module was launched, 2,803 grants were 

closed out late. (See Table 3.) 

Calendar Year of the 

Project Period End 

Date 

Number of Closeouts 

in Module 

Number of Late 

Closeouts in Module 

Percent of Late 

Closeouts in the 

Module 

1994 8 8 100% 

1995 217 216 100% 

1996 401 396 99% 

1997 454 439 97% 

1998 690 670 97% 

1999 1,352 1,318 98% 

2000 1,711 1,528 89% 

2001 1,756 1,563 89% 

2002 3,425 2,803 82% 

2003 103 0 0% 

No year provided 5 n/a n/a 

Overall Total 10,122 8,941 88% 

Table 3. Late Closeouts by Project Period End Date 

Source:OIG analysis of data from NIH's Closeout Module, 2003 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 9 
FINDINGS 

Twenty-three institutes have used the closeout module to varying 

degrees. Considering the varying approaches to entering data into 

the closeout module, it is difficult to look at the trend of closeouts 

across the institutes. Some institutes have entered as few as 2 grants 

(National Institute on Drug Abuse) while others have entered over 

2,000 (National Institute of Neurological Disorders and Stroke). 10 

Fourteen institutes have at least 100 late closeouts in the module. 

(See Appendix C.) Of the institutes that have the most closeouts in 

the module (500 or more grants in the module), the proportion of late 

closeouts ranged from 55 to 100 percent. (See Table 4.) Although it 

has provided training on the use of the closeout module to institute 

staff, at the time of our review, NIH did not require institutes to use 

the module. 

Institute or Center Number of Closeouts 

in the Module 

Number of Late 

Closeouts in the 

Module 

Percent of Late 

Closeouts in the 

Module 

Nat. Inst. of Neurological Disorders & Stroke 2,016 1,887 94% 

Nat. Cancer Institute 1,228 1,108 90% 

Nat. Inst. of Child Health & Human Development 964 953 99% 

Nat. Inst. on Deafness and other Communication Disorders 1,008 922 92% 

Nat Inst. Of Allergy & Infectious Diseases 1,060 917 87% 

Nat. Inst. of Dental & Craniofacial Research 593 584 99% 

Nat. Heart, Lung, & Blood Institute 621 566 91% 

Nat. Center for Research Resources 1,005 557 55% 

Nat. Inst. of Diabetes & Digestive & Kidney Diseases 541 540 100% 

Table 4. Late Closeouts for the Institutes with the Most Grants in the Closeout Module 

Source: OIG analysis of data from NIH's Closeout Module, 2003 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 10 
FINDINGS 

Federal regulations require 

Grantees submitting closeout documents late is grantees to submit all closeout 

the primary cause for late closeouts. documents no later than 90 

calendar days following the 

termination of a grant.11 

Financial status reports were submitted late most often. Based on data 

from the closeout module, grantees submitted final financial status 

reports late for 49 percent of grants that were closed out late. On 

average, financial status reports were at least 191 days late. 

Grantees submitted final progress reports late in 37 percent of grants 

closed out late, averaging at least 467 days late. The closeout module 

does not have a date for final invention reports, as the module was not 

designed to capture it. Instead, the receipt is indicated by a “Yes” or 

“No.” Therefore, it is difficult to accurately report the extent of late 

invention statements. However, grantees submitted at least 31 

percent of final invention statements late of grants closed out late. 

This is assuming that all grants with a “Yes” were received on time, 

which is unlikely. (See Table 5.) Grantees submitted at least 2 of the 

documents late in 35 percent of the grants closed out late, and 5 

percent of grantees submitted all three documents late. 

Document Percent Late 

No 

Information in 

Module* 

Percent on 

Time 

Financial Status Report 49% 26% 26% 

Progress Report 37% 54% 9% 

Invention Statement 31% 31% 31% 

Table 5. Percent of Late Closeout Documents 

Source: OIG analysis of data from NIH's Closeout Module, 2003 

*No information could reflect that the institute has not received the information 

from the grantee or that the system has not been updated to reflect the receipt. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 11 
FINDINGS FINDINGS 

Grantees experience several challenges in submitting closeout 

documents on time. Eighty-five percent of grantee institutions 

indicated that they had submitted at least one closeout package late 

in the past 3 years. Several reasons may account for this. First, 

grantee institutions commented on our survey that 90 days is not 

always enough time to reconcile accounts and prepare the financial 

status report, especially when subgrantees are involved. Second, they 

also acknowledged that they have difficulty obtaining the necessary 

information in a timely manner from principal investigators at their 

institutions, who are often busy with other grants and may not view 

the final progress report as a high priority. Third, grantee 

institutions commented that limited staff resources and other 

competing priorities hinder their ability to stay on top of closeouts, 

especially as late closeouts accumulate. And finally, grantees must 

submit their invention statements and progress reports on paper 

through regular mail. Only financial status reports can be submitted 

electronically to NIH. Paper submission may contribute to late 

closeouts. 

NIH lacks a reminder system to alert grantees about upcoming due 

dates for closeouts. As the end of the project period nears, NIH does 

not routinely send a reminder or notice to the grantee about the 

upcoming due date for closeout documents. Instead, NIH informs the 

grantee in the notice-of-grant award for the last budget period, which 

is typically a year before the closeout documents are due. Grantee 

institutions that responded to our survey commented that the lack of 

reminders immediately prior to due dates contributed to late closeout 

documents. 

When grantees submit closeout documents on time, NIH does close out 

the grant in a timely manner. Based on data from the closeout module, 

we found that when all closeout documents were submitted within 90 

calendar days, NIH reviewed and approved the documents within 60 

days 96 percent of the time. Seventeen of the 24 institutes with 

grant-making authority have procedures to manage closeouts.* 

* Since the time of our review, NIH has centralized its grants closeout function, such that 

individual institute’s procedures are being replaced by standard operating procedures. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 12 
FINDINGS 

Tracking down missing closeout documents As late closeouts accumulate, 

institute staff commented that 

requires significant time and effort by the they find it difficult to address 

institutes. the backlog given other 

competing priorities, especially issuing new grants. They also raised 

concerns about the amount of resources they have to manage the 

closeout process and follow-up with grantees regarding late closeout 

documents. Obtaining missing closeout documents is especially 

difficult for grants that are several years old, because principal 

investigators may have moved on to other institutions and records 

may not be readily available. 

To address this workload, the three institutes we reviewed in-depth 

(the National Heart, Lung, and Blood Institute; the National Institute 

of Allergy and Infectious Diseases; and the National Institute of 

General Medical Sciences) hired contractors or staff, who are 

dedicated solely to processing closeout documents from grantees. The 

chief grants management officers at these three institutes mentioned 

dedicated staff as key for processing closeouts, especially the backlog 

of late closeouts. 

In order to obtain missing documents, institutes must follow up, often 

multiple times, with grantees. The NIH Manual recommends 

institutes follow-up with grantees if the closeout documents have not 

been submitted after 90, 120, and 150 calendar days. 12 

The closeout module allows institutes to record up to two follow up 

correspondences with grantees. Because we could not readily obtain 

the correspondence data for all grants in the closeout module, we 

reviewed printouts that contained correspondence data for a sample of 

300 out of 1,560 grants that were closed out late in FY 2002 at the 

National Heart, Lung, and Blood Institute, the National Institute of 

Allergy and Infectious Diseases, and the National Institute of General 

Medical Sciences. We found that 80 percent of these grants had at 

least 1 recorded correspondence in the closeout module, and 39 

percent had a second recorded correspondence. It is possible that 

institutes conducted additional follow-up that was not recorded in the 

closeout module. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 13 
FINDINGS FINDINGS 

NIH experiences several challenges in taking According to the NIH Manual, 

corrective actions against grantees for institutes may impose one of 

several sanctions if the submitting closeout documents late. grantee has not submitted its 

closeout documents within 150 days. 13 If the principal investigator 

has other pending awards with the same institute, the institute may 

withhold future funding from the grantee institution for that 

particular principal investigator until the closeout documents are 

submitted. If the principal investigator has other pending awards at 

other institutes, the institute with the late closeout could request that 

the other institutes also withhold future funding from the principal 

investigator’s institution. However, it is up to each individual 

institute to determine whether or not to withhold future funding. 

Because the closeout module does not capture such information, we 

were unable to quantify how often institutes withheld future funding. 

However, in interviews, institute staff indicated that they rarely 

resort to withholding future funding from a principal investigator due 

to late closeouts, because it is viewed as too severe a penalty and 

slows down future research. Withholding funds often means 

coordinating with other institutes where the principal investigator 

and grantee institution has pending awards, which can be difficult. 

And in many cases, the option of withholding future funds is not 

possible, as the principal investigator is no longer conducting any 

NIH-funded research. 

Even though we are unable to quantify definitively the number of 

times NIH withheld future funding, 12 percent of grantee institutions 

reported to us that NIH had withheld future funding from their 

institutions due to late submission of closeout documents. However, 

86 percent of grantee institutions indicated that they had submitted 

at least 1 set of closeout documents late in the past 3 years. 

Besides withholding future funding, NIH can impose special award 

conditions on the grantees, such as additional monitoring, for grantee 

institutions with a history of poor performance. 14 However, NIH’s 

policy makes no explicit mention of imposing special conditions. 15 

Instead, it discusses the possibility of taking corrective actions when 

there is a pattern of late closeouts, but it provides few specifics about 

what type of corrective actions are appropriate and when they should 

be taken. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 14 
FINDINGS FINDINGS 

The closeout module is NIH’s 

While the closeout module is promising, it has main effort to help reduce late 

some limitations. closeouts. While the closeout 

module is designed to facilitate 

the closeout process, current limitations hinder its ability to do so. 

Institute staff manually enter grants ready for closeout into the 

module; therefore, completeness is dependent on the staff updating 

the system. (Manual entry is necessary in order to verify the grant is 

ready for closeout.) Based on the number of records entered in the 

module, some institutes are clearly using the module more than 

others. For example, the National Institute of Neurological Disorders 

and Stroke has over 2,000 grants entered in the module while the 

National Institute on Drug Abuse only has 2. As we have already 

indicated, at the time of our review, NIH did not require institutes to 

use the module. 

Even for those institutes that have entered information, it is 

uncertain how diligent they are at keeping the information up to date. 

Many of the records contain missing information, which raises 

questions about whether the information was not submitted to the 

institute or whether the institute failed to enter it. Data on the 

progress report are the most commonly missing information (54 

percent were blank), followed by data on the invention statement (31 

percent were blank), and the financial status report (26 percent were 

blank). (See Table 5 on page 11.) 

In addition, as we have already pointed out, the closeout module 

records only two dates of correspondence between the institute and 

the grantee and does not record any corrective or enforcement actions 

taken by the institutes. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 15 
RECOMMENDATIONS

In NIH’s closeout module we found 8,941 late closeouts. This 

presents a vulnerability to NIH, as closeouts are the final point of 

accountability for the grantee. NIH staff spend significant time and 

effort following up with grantees to obtain late closeout documents. 

As for the grantees, late closeouts can jeopardize their future funding. 

NIH is taking important steps toward addressing this problem, 

especially by implementing the closeout module. In addition, NIH 

plans to manage the closeout process from a new central office; this 

approach will help to bring additional attention to closeouts as well as 

create efficiencies. NIH also plans to address closeouts more 

systematically by following up with grantee institutions that have a 

pattern of late closeouts. NIH will continue to conduct outreach to 

grantees about the importance of on-time closeouts and plans to 

require institutes to use the closeout module. Finally, NIH has a 

workgroup as part of its Compliance, Education and Review Team, 

that is examining ways to improve the closeout process. We 

encourage NIH to continue these efforts. 

We also offer four recommendations to NIH on how to further address 

late closeouts. 

Develop an automated reminder system for Given that grantees regularly grantees to alert them of upcoming closeouts. fail to submit closeout 

documents on time, an 

automatic reminder system could be a simple yet beneficial way to 

foster grantee compliance. NIH has already developed an automatic 

email notification system to remind principal investigators about 

upcoming due dates for noncompeting applications, which NIH 

requires at the end of each budget period to renew funding. NIH could 

use a similar system to remind grantees about upcoming due dates for 

closeout documents. This reminder should be sent to both the 

principal investigator and the appropriate business official at the 

grantee institution. 

NIH is moving towards

Facilitate the electronic submission of all electronic grants 

closeout documents. management to facilitate 

other parts of the grantmaking process. We suggest that NIH also include the closeout 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 16 
RECOMMENDATIONS 

process by developing a system by which grantees can submit all 

closeout documents electronically to NIH. Currently only the 

financial status reports can be submitted electronically. The 

electronic submission of closeout documents should help to facilitate 

on-time closeouts. 

NIH has taken an important 

Enhance the closeout module’s capabilities. step toward addressing late 

closeouts by implementing 

the closeout module. We 

recognize that NIH continues to make improvements to the module 

and we believe that this module has the potential to help NIH address 

late closeouts. However, as we have pointed out, not all institutes are 

using it to the fullest extent possible. We recognize that at the time 

we conducted our review the module was less than a year old, and 

therefore institutes may not have been fully aware of how best to use 

it. 

It is important that NIH ensure that all the information in the 

module is up-to-date by requiring all closeouts to be entered into the 

system. We encourage NIH to proceed with its plans to require all 

institutes to use the module. In addition, to ensure the integrity of 

the data, NIH should conduct regular validity checks of the system. 

Not only should NIH ensure the information in the module is 

complete and up-to-date, but it should also improve the structure of 

the closeout module. First, NIH should capture the date of receipt of 

the final invention statement. Currently, this information is not 

recorded in the system. Second, we recommend that NIH capture 

additional dates of correspondence. The current version only allows 

institutes to record up to two dates of correspondence. Institute staff 

indicated that more follow-up is often necessary. Third, we 

recommend that NIH create a field to capture any type of corrective or 

enforcement action that has been taken. This will allow NIH to 

monitor these actions across all institutes and ensure consistency. 

Fourth, we recommend NIH improve the reporting functions of the 

closeout module so that NIH staff can more readily identify patterns 

of late closeouts for grantee institutions and/or principal 

investigators. 

Finally, we encourage NIH to proceed with its plans to make this 

module available for grantees to access on a read-only basis. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 17 
RECOMMENDATION RECOMMENDATIONS

Providing this closeout information will allow grantees to take a more 

active role in monitoring their own closeouts. 

We found that 50 grantee

Address late closeouts more systematically by institutions represent 45 

focusing on grantee institutions. percent of the late closeouts 

in the module. Efficiencies 

could be gained if NIH followed up with key administrators at these 

institutions, rather than having institute staff follow up on individual 

grants. NIH should routinely identify patterns of late closeouts by 

grantee institutions and principal investigators. We recognize NIH 

plans to move in this direction and we encourage NIH to do so. 

Ideally, the new central office managing closeouts could identify these 

patterns across all of NIH. 

Once NIH identifies either a principal investigator or a grantee 

institution with a pattern of late closeouts, it should take appropriate 

corrective actions to address the situation. In addition to withholding 

any future funding from individual principal investigators at 

particular grantee institutions, we suggest that NIH consider 

providing technical assistance to grantee institutions with a pattern 

of late closeouts. This could be accomplished through general 

outreach efforts or through targeted follow-up with individual 

grantees. This could involve a review of the grantee institutions’ 

policies and procedures for processing closeouts internally and 

training for principal investigators and other key staff. 

NIH should also consider using its authority to impose special 

conditions on grantee institutions with poor performance, to address 

late closeouts. In order to do so, NIH should identify what special 

conditions are appropriate for grantee institutions with a pattern of 

late closeouts. 16 

Agency Comments 

NIH reviewed a draft of this report and concurred with our 

recommendations. In its comments, NIH indicated additional steps that 

it is planning to address these issues, such as requiring the inclusion of 

all grants expiring on or after October 1, 2004 in the closeout module 

and centralizing the grants closeout function. We appreciate NIH’s 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 18 
attention to these important issues. For the full text of the agency’s 

comments, see Appendix D. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 19
� APPENDIX ~ A

Methodology 

NIH Closeout Module Data Analysis 

The National Institutes of Health (NIH) provided us with records of all 

grants in the closeout module as of April 2003. The records supplied 

from the module originated from the database management system 

known as the Information for Management, Planning, Analysis, and 

Coordination (IMPAC II). NIH uses IMPAC II for managing and 

monitoring grants. NIH has used IMPAC II for managing and 

monitoring grants for the past 10 years. 

We received a dataset of 10,130 records. For each grant, the dataset 

included the grant number, grantee institution name and identification 

number, grant mechanism and type, total award amount, awarding 

institute, budget end date, project end date, final financial status report 

receipt date, final financial status acceptance date, final progress report 

date, final invention statement receipt (yes/no), and grant closeout date. 

We eliminated eight grants from our analysis because of missing 

information or apparent data entry errors. The revised dataset had a 

total of 10,122 records. 

In consultation with NIH, we classified a closeout as late if the closeout 

date was 150 days or more after the project end date. The grantee has 

90 calendar days to submit the closeout documents (final financial 

status report, final progress report, and final invention statement) 

following the termination of the grant. In addition, we added 60 

calendar days to allow NIH staff to review and approve the documents 

submitted by the grantees. 

We tallied the number of late closeouts overall, as well as by year, by 

grantee institution, by institute, by grant mechanism, and by number of 

months/years late. We performed our analyses using SAS® software 

version 8.0, a statistical software package. 

Data limitation. NIH’s closeout module allows the institutes to track 

grants that are ready for closeout. In order for a grant to be captured in 

the closeout module, institute staff must enter the grant in the module. 

Because the module depends on someone to enter the grants, it is 

unlikely that the module contains all grants ready for closeout. This is 

further complicated by the fact that at the time of our review, the 

module had been in use for only about 8 months, and institutes use it to 

varying extents. For example, some institutes have entered closeouts 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 20 
APPENDIX~A 

from the past several years, whereas other institutes have only entered 

the most recent closeouts. Therefore, we cannot make any conclusions 

about the entire population of closeouts based solely on that data. This 

limitation applies to all data analysis based on the closeout module. 

NIH Closeout Module Correspondence Analysis 

We obtained computer printouts from the closeout module for a 

stratified sample of 300 grants that were closed out late (at least 150 

days after the project end date) or were still open at least 150 days after 

the project end date. From these printouts, we obtained the dates of 

the correspondence from the institutes to the grantees to obtain missing 

closeout documents. We relied on these printouts because we could not 

readily obtain this information electronically for all grants in the 

closeout module. 

In order to concentrate on the most prominent funding sources, we 

limited our population to three of the largest institutes: National Heart, 

Lung, and Blood Institute, the National Institute of Allergy and 

Infectious Diseases, and the National Institute of General Medical 

Sciences. (For fiscal year (FY) 2002, these three institutes were in the 

top four in terms of number of extramural research grants and amount 

funding for extramural research grants.) We excluded the largest 

institute, the National Cancer Institute, because it already has an 

active monitoring system in place to identify late closeouts and their 

causes. We stratified our sample by institute. (See Table 6.) 

Strata for File Review 

Population of 

Late 

Closeouts 

Sample of 

Late 

Closeouts 

National Heart, Lung, & Blood Institute 522 100 

National Institute of Allergy & Infectious Diseases 784 100 

National Institute of General Medical Sciences 254 100 

Total 1,560 300 

Table 6. Sample Design 

Source: OIG analysis, 2003 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 21 
APPENDIX~A 

For each of the 300 late closeouts, we recorded the follow-up the 

institutes had with the grantee to obtain the closeout documents. We 

noted the dates of any letters sent to the grantee and any comments 

added to the remarks section. We analyzed the data to determine what 

percent of late closeouts received one follow-up and what percent of late 

closeouts received a second follow-up. 

Institute Procedure Review 

We requested operating procedures related to closeouts from all 

24 institutes with grant-making authority. Seventeen of the 

24 institutes with grant-making authority provided us with materials; 

the other 7 (National Institute of Child Health and Human 

Development, National Center for Complementary and Alternative 

Medicine, National Institute of Biomedical Imaging and 

Bioengineering, National Eye Institute, National Institute on Aging, 

National Institute of Nursing Research, and National Center on 

Minority Health and Health Disparities) did not maintain operating 

procedures specific to closeouts at the time of our review. We included 

in our review any written procedures, instruction manuals, checklists, 

worksheets, timelines, flowcharts, and form letters sent to us by the 

institutes. We assessed the number of institutes that maintained 

guidelines related to (1) tracking closeouts, (2) following up with 

grantees, and (3) instructions on the closeout process. 

Survey of NIH Grantee Institutions 

We selected a simple random sample of 135 grantee institutions from the 

375 locations that received 10 or more research grants from NIH in FY 

2002. We restricted our sample to institutions with 10 or more research 

grants to ensure that they had a wide range of experiences with NIH, so 

that any problems they reported with closeouts would not reflect an 

anomaly. We drew our sample from a list of 2,532 institutions provided 

by NIH. 

We oversampled by an additional 18 locations in order to obtain our 

desired sample size. From 153 grantee institutions, we eliminated 2 

foreign institutions, 2 institutions with incomplete contact information, 

and 14 duplicates (where 2 or more divisions of a research institution 

were included in our sample, we kept only the first entry in order to avoid 

duplication.) 

The survey contained seven questions on late closeouts, which 

addressed the main factors that cause late closeouts, the extent to 

which late closeouts create problems, and recommendations for 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 22 
APPENDIX~A 

improving the closeout process. We pretested our survey with grantee 

institutions. 

We addressed the survey to the business official identified by NIH. In 

cases where NIH had not identified a business official, we addressed 

the survey to a senior grants administrator. In both instances, we 

indicated in our cover letter that a senior grants administrator who is 

knowledgeable about NIH grants was to complete the survey. 

To ensure a high response rate, we first sent an introductory letter to 

each institution in our sample, explaining the significance of the 

survey. One week later, we mailed the survey. We followed up with a 

second survey for institutions that did not send back our survey within 

3 weeks. 

We received 111 responses to our survey, for a response rate of 82 

percent. Nonrespondent analysis found no significant difference 

between respondents and nonrespondents in terms of average number 

and funding of research awards. The estimates given in the report are 

within plus or minus 7 percentage points at the 95 percent confidence 

level (See Table 7 below and Table 8 on the following page.) 

Average Number of Awards 

Sample (n=135) 108 

Respondents (n=111) 107 

Nonrespondents (n=24) 112 

t=0.15 Degrees of freedom=133 

Table 7. Nonrespondent Analysis by Number of 

Research Awards 

Source: OIG survey of NIH grantees, 2003 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 23 
APPENDIX~A 

Average Amount of Funding 

Sample (n=135) $37,550,528.82 

Respondents (n=111) $37,303,671.78 

Nonrespondents (n=24) $38,692,242.60 

t=0.12 Degrees of freedom=133 

Table 8. Nonrespondent Analysis by Amount of 

Funding 

Source: OIG survey of NIH grantees, 2003 

Interviews of NIH officials 

We interviewed a program officer, a grants management specialist, and 

the chief grants management officer at the National Heart, Lung, and 

Blood Institute, the National Institute of Allergy and Infectious 

Diseases, and the National Institute of General Medical Sciences. We 

discussed the causes and effects of late closeouts, any systems that the 

institutes had in place to track and monitor closeouts, and any barriers 

to closing out grants on time. We also solicited their recommendations 

for improving the closeout process and the closeout module. 

We also spoke with staff at the Office of Extramural Research and with 

institute administrators involved in NIH-wide grants administration 

efforts, who described the initiatives that NIH has planned or 

underway to reduce the likelihood of closeouts. We discussed the 

causes and effects of late closeouts, and any barriers to closing out 

grants on time. We also solicited their recommendations for improving 

the closeout process. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 24 
� APPENDIX ~ B

Confidence Intervals for Key Findings 

Below, we provide the point estimate and 95 percent confidence interval 

for each of our key findings. The point estimates and confidence 

intervals for the findings vary based on the standard error for each 

individual finding. 

Data Source Key Findings Sample 

Size 

Point 

Estimate* 

Confidence 

Interval 

Percent of grants with at least 1 

recorded correspondence in the 

closeout module 

NIH closeout module 300 80% +/- 5%

correspondence analysis 

Percent of grants with at least 2 

recorded correspondence in the 

closeout module 

300 39% +/- 6% 

*Note: Point estimates are weighted. 

Source: OIG analysis, 2003 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 25 
� APPENDIX ~ C

Late Closeouts for All Institutes in the NIH Closeout 

Module* 

Institute/Center 

Number of 

Closeouts in the 

Module 

Number of Late 

Closeouts in the 

Module 

Percent of Late 

Closeouts in the 

Module 

National Institute of Neurological Disorders & Stroke 2,016 1,887 94% 

National Cancer Institute 1,228 1,108 90% 

National Institute of Allergy & Infectious Diseases 1,060 917 87% 

National Institute on Deafness & Other Communication Disorders 1,008 922 92% 

National Center for Research Resources 1,005 557 55% 

National Institute of Child Health & Human Development 964 953 99% 

National Heart, Lung, & Blood Institute 621 566 91% 

National Institute of Dental & Craniofacial Research 593 584 99% 

National Institute of Diabetes & Digestive & Kidney Diseases 541 540 100% 

National Institute of General Medical Sciences 386 323 84% 

National Institute of Nursing Research 169 156 92% 

Fogarty International Center 154 131 85% 

National Institute of Mental Health 120 108 90% 

National Institute of Arthritis & Musculoskeletal & Skin Diseases 113 112 99% 

National Institute on Alcohol Abuse & Alcoholism 51 17 33% 

National Library of Medicine 28 15 54% 

National Human Genome Research Institute 21 7 33% 

National Institute on Aging 12 12 100% 

National Center for Complementary & Alternative Medicine 12 12 100% 

National Eye Institute 10 10 100% 

National Institute of Biomedical Imaging & Bioengineering 6 0 0% 

National Institute on Drug Abuse 2 2 100% 

National Institute of Environmental Health Sciences 2 2 100% 

Overall Total 10,122 8,941 88% 

Source: OIG analysis of data from NIH's Closeout Module, 2003 

*24 ICs have grant-making authority but the National Center for Minority Health and Health Disparities was established in 2000 

and has not yet closed out a grant. 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 26
� APPENDIX ~ D

Agency Comments

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 27
APPENDIX~D 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 28
APPENDIX~D 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 29
APPENDIX~D 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 30
� ACKNOWLEDGMENTS

This report was prepared under the direction of Mark R. Yessian, Ph.D., 

Regional Inspector General for Evaluation and Inspections in the Boston 

Regional Office, and Joyce M. Greenleaf, MBA, Assistant Regional 

Inspector General. Other principal Office of Evaluation and Inspections 

staff who contributed include: 

Aimee Golbitz, Project Leader 

Danielle Fletcher, Program Analyst 

Sara Schulman, Program Analyst 

Genevieve Nowolinski, Program Specialist 

Ayana Everett, Program Specialist 

Elise Stein, Director, Public Health and Human Services 

Technical Assistance 

Barbara Tedesco, Mathematical Statistician 

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 31 
� END NOTES

1 U.S. Department of Health and Human Services, Performance and 

Accountability Report Fiscal Year 2002, Appendix A. 

2 45 CFR § 74 and 92. 

3 NIH Grants Policy Statement, March 2001, p. 25. 

4 NIH is comprised of 27 institutes and centers, such as the National 

Cancer Institute. Only 24 institutes have grant-making authority. 

5 45 CFR § 74.70-73. 

6 NIH Manual, 5805-Closeout of NIH Grants, Release Date 2/16/00. 

7 U.S. Department of Health and Human Services FY 2002 

Performance and Accountability Report, Independent Auditor’s 

Report and Management Response, p. 12. 

8 General Accounting Office, NIH Research: Improvements Needed in 

Monitoring Extramural Grants (GAO/AIMD-00-139), May 2000. 

9 National Cancer Institute, Office of Management, Grants 

Administration Branch Business Plan, February 2002. 

10 There are 24 institutes with grant-making authority. However, the 

National Center on Minority Health and Health Disparities was 

established in 2000 and has not yet closed out a grant. 

11 45 CFR § 74.70-73. 

12 NIH Manual, 5805-Closeout of NIH Grants, Release Date 2/16/00. 

13 NIH Manual, 5805-Closeout of NIH Grants, Release Date 2/16/00. 

14 45 CFR § 74.14. 
EENDNOTES 

15 NIH Manual, 5805-Closeout of NIH Grants, Release Date 2/16/00. 

16 45 CFR § 74.14.

OEI - 01 - 03 - 00021 NIH GRANTS M ANAGEMENT : LATE CLOSEOUTS 33