Post Award

NIH Grants: Key Information

Changes in Project and Budget

Prior Approval Requirements

Expanded Authorities

Requests for Approval


Changes in Project and Budget

In general, NIH grantees are allowed a certain degree of latitude to rebudget within and between budget categories to meet unanticipated needs and to make other types of post-award changes.  Some changes may be made by the grantee only within limits established by NIH.  Other changes require NIH prior written approval before modifying the budget or undertaking the activity in question.  The degree of discretion permitted varies by type of grant, grantee, and coverage by, or participation in, a special initiative.  The grantee-initiated changes that may be made under the grantee’s authority and the changes that require NIH approval are outlined below with respect to particular types of awards, activities, or recipients.  In addition, individual awards my restrict grantees’ authorities to make budget and project changes without NIH prior approval.  If NIH approval is required, it must be requested of, and obtained from, the designated NIH GMO in advance of the change or obligation of funds as specified below under “Requests for Approval.”

Changes in project or budget resulting from NIH-initiated changes are also discussed below.

 

Prior Approval Requirements

The following table applies to NIH research grants and cooperative agreements to domestic organizations.  The table lists the activities and/or expenditures that require GMO prior approval in accordance with the general terms and conditions of award (e.g. Expanded Authorities, Federal Demonstration Partnership (FDP), or the terms and conditions of the NIH policy statement) and also includes activities and/or expenditures where NIH has waived the prior approval requirement on a class basis.  The information in this table is for guidance purposes only.  Any question about the need for prior approval for an activity or cost under a specific NIH award should be directed to the PAF Team, who will follow up with the designated GMO.

NIH Prior Approval is Required for:Under the Following Circumstances:
Additional no-cost extension, extension greater than 12 months, or late notification of initial no-cost extension All instances.
A&R (Alterations and Renovations) Rebudgeting into A&R costs that would exceed 25 percent of the total approved budget for a budget period.

If rebudgeting would not meet this threshold but would result in a change in scope.

Any single A&R project exceeding $500,000.
Capital expenditures (construction, land, or building acquisition) All instances. Also, any proposals to convey, transfer, assign, mortgage, lease, or in any other manner encumber real property acquired with NIH grant funds.
Carryover of unobligated balances If the NoA indicates that the grantee does not have the authority to automatically carry over unobligated balances.
Change in scope All instances.
Change in status of the PD/PI or senior/key personnel named in the NoA Withdrawal from the project; absence for any continuous period of 3 months or more; reduction of the level of effort devoted to project by 25 percent or more from what was approved in the initial competing year award.
Change of grantee organization All instances.
Change of grantee organization status All instances.
Deviation from award terms and conditions All instances. Includes undertaking any activities disapproved or restricted as a condition of the award.
Foreign component added to a grant to a domestic or foreign organization All instances.
Need for additional NIH funding All instances, including extension of a final budget period of a project period with additional funds.
Pre-award costs More than 90 days before effective date of the initial budget period of a new or competing continuation award; always at the grantee's own risk.
Rebudgeting funds from trainee costs All instances.
Rebudgeting of funds between construction and non-construction work All instances.
Retention of research grant funds when CDA awarded All instances.

Expanded Authorities

Federal administrative requirements allow agencies to waive certain cost-related and administrative prior approvals; these are known as expanded authorities. In 2001, NIH extended expanded authorities to all NIH awards except for the provision to automatically carry over unobligated balances. Certain award instruments, grant programs, and types of recipients are routinely excluded from the authority to automatically carry over unobligated balances. This includes centers (P50, P60, P30, and others); cooperative agreements (U); Kirschstein-NRSA institutional research training grants (T); non-Fast Track Phase 1 SBIR and STTR awards (R43 and R41); clinical trials (regardless of activity code); and awards to individuals.

One or more of these authorities may be overridden by a special term or condition of the award. Grantees must review the NoA to determine if a particular authority is withheld for a specific grant.

Grantees must exercise proper stewardship over Federal funds and ensure that costs charged to awards are allowable, allocable, reasonable, necessary, and consistently applied regardless of the source of funds. NIH may disallow the costs if it determines, through audit or otherwise, that the costs do not meet the tests of allowability, allocability, reasonableness, necessity, and consistency.

Several authorities have specific deadlines for submission of reports or for timely notification to the NIH awarding IC. Grantees should be aware that any consistent pattern of failure to adhere to those deadlines for reporting or notification will be grounds for excluding that grantee from a specific authority.

Grantee Authorities as NIH Standard Terms of AwardExceptions
Carryover of unobligated balances from one budget period to any subsequent period Centers (P50, P60, P30 and others), cooperative agreements (U), Kirschstein-NRSA institutional research training grants (T), non-Fast Track Phase I SBIR and STTR awards (R43 and R41), clinical trials, and awards to individuals, or if the NoA indicates otherwise.
Cost-related prior approval changes, including research patient care costs and equipment The cost would result in a change of scope.
Extension of final budget period of a project period without additional NIH funds (no-cost extension) The grantee has already exercised its one-time authority to extend the award for up to 12 months.
Transfer of performance of substantive programmatic work to a third party (by consortium agreement) The transfer would be to a foreign component or it would result in a change in scope.

Extension of a Project Period Without Additional Funds:  

The grantee may extend the final budget period of the project period one time for a period of up to 12 months beyond the original expiration date shown in the NGA if no additional funds are required to be obligated by the NIH awarding office, there will be no change in the project’s originally approved scope, and any one of the following applies:

 

  • Additional time beyond the established expiration date is required to ensure adequate completion of the originally approved project.

 

  • Continuity of NIH grant support is required while a competing continuation application is under review.

 

  • The extension is necessary to permit an orderly phase-out of a project that will not receive continued support.

 

The fact that funds remain at the expiration of the grant is not, in itself, sufficient justification for an extension without additional funds.

 

The grantee must notify the NIH awarding office, in writing, of the extension ten days prior to the expiration date of the project period.  Upon notification, the NIH awarding office will revise the project period ending date and provide an acknowledgement to the grantee.  In extending the final budget period of the project period through this process, the grantee agrees to update all required certifications, including human subjects and animal welfare, in accordance with the applicable regulations and policies.  Grantees may not extend project periods previously extended by the NIH awarding office.  Any additional project period extension beyond the one-time extension of up to 12 months requires NIH prior approval.  (See the  “Prior Approval Requirements” section above.)

 

Carryover of Unobligated Balances:  

Except for funds restricted in an NGA, unobligated funds remaining at the end of a budget period are automatically carried over.  For awards under the Streamlined Non-Competing Award Process (SNAP), funds are automatically carried over and are available for expenditure during the entire project period.  However, under those awards, the grantee will be required to indicate, as part of its non-competing continuation request, whether its estimated unobligated balance (including prior year carryover) is expected to be greater than 25% of the current year’s total budget.  If so, the grantee must provide an explanation and indicate plans for expenditure of those funds if carried forward.  (See the NIH’s website under “Administrative Requirements – Non-Competing Continuation Awards.”) 

 

For those awards subject to expanded authorities but excluded from SNAP (e.g. P01s and R35s), the FSR must specify the amount to be carried over.  The notification must be provided under item 12, “Remarks,” on the FSR.  When a grantee reports a balance of unobligated funds in excess of 25% of the total amount awarded, the GMO will review the circumstances resulting in the balance to ensure that these funds are necessary to complete the project, and may request  additional information from the grantee, including a revised budget, as part of the review.  If the GMO determines that some or all of the unobligated funds are not necessary to complete the project, the GMO may take one, or a combination, of the following actions:

 

  • Restrict the grantee’s authority to automatically carry over unobligated balances in the future.

 

  • Use the balance to reduce or offset NIH funding for a subsequent budget period.  Any amount not identified for carryover may be used as an offset.  A revised NGA will not be issued to reflect the carryover.

 

Use of Program Income: The additive costs alternative for the use of program income applies to awards subject to expanded authorities unless the NGA specifies another alternative or the grantee is a for-profit organization other than an SBIR/STTR awardee.  For-profit organizations other than SBIR/STTR awardees are subject to the deductive alternative.  (See the NIH’s website under “Administrative Requirements – Management Systems and Procedures – Program Income.”)

 

Transferring the Performance of Substantive Programmatic work to a Third Party by Means of a Consortium Agreement, Contract, or Other Means:  Under expanded authorities, a grantee is not required to obtain NIH prior approval for transferring the performance of substantive programmatic work unless the activity constitutes a change in scope or results in the transfer of substantive programmatic work to a foreign component.

 

Cost-Related Prior Approvals, including Patient Care and Equipment:  Requirements for NIH approval of incurrence of these individual costs, including rebudgeting for them, do not apply under expanded authorities unless they constitute a change in scope.

 

Requests for Approval

All requests for NIH awarding office prior approval must be made, in writing (which includes submission by email) to the designated GMO no later than 30 days before the project termination date.

Note: Send all requests to the PAF Team who will ensure it gets to the funding agency.