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Policy Update
What’s New?IHS Grants Policy Source DocumentsPolicy TopicsPrior ApprovalReporting RequirementsCloseout
What’s New?
Grants Policy Statement
U.S. Department of Health and Human ServicesOffice of the Assistant Secretary for Resources and Technology
Office of Grants
October 1, 2006
What’s New?HHS Grants Policy Statement
Effective: October 1, 2006
Applicability: HHS Operating Divisions and Staff Divisions that issue Discretionary Grant Awards w/the exception of NIH.
Makes available to HHS grantees, in a single document, up-to-date policy guidance.
IHS Grants Policy Source Documents
Grants Policy DirectivesAwarding Agency Grants
Administration Manual (AAGAM)Policy Announcements – “coming
soon”45 CFR 74 and 92HHS Grants Policy StatementIndian Health Service Circular
Cost Principles
OMB Circular A-87: State, Local, and Indian Tribes
OMB Circular A-122: Non-profit OrgsOMB Circular A-133: AuditsOMB Circular A-102: AdministrativeOMB Circular A-122: Administrative
Requirements
Cost Principles What are the Cost Principles?
Establish principles to determine cost applicability to grants, contract & other agreements
Designed to ensure that the Federal Government provide its fair share of total costs
In accordance with generally accepted accounting principles
What’s Included in the Cost Principles?
Covers allowability of costs Costs must be reasonable Costs must be allocable Costs must be given consistent treatment Costs must conform to any limitations or exclusions
Provides guidance for institutions to annually disclose cost accounting practices (disclosure statement)
Provides guidance for Direct Costs which are costs that can be readily identified w/a particular sponsored project…or that can be directly assigned to such activities relatively easily w/a high degree of accuracy
What’s Included in the Cost Principles?
Comprehensive instructions and/or information issued by OMB to all Federal agencies.
Grants policy related circulars include: 1) Administrative requirements (A-110 & A-102)
A-110 now found at 2 CFR, Chapter II, Pt 215 2) Cost Principles (A-122 & A-87)
A-122 now found at 2 CFR, Chapter II, Pt 230 A-87 now found at 2 CFR, Chapter II, Pt 225
3) Audit requirements (A-133)
Target Audience: Federal agencies and grantee organizations
Cost related Requirements for Grantees
Costs must be related to the project charged
Costs must be reasonable - prudent person test
Costs related to multiple projects allocated:
on proportional benefit, where possible on any reasonable basis, where
necessary
Grants Management 101Definitions of Frequently Used Terms Used
Unobligated Balance
Unliquidated Obligations
Prior Approval
Change in Scope
Significant Rebudgeting
Definitions of Frequently Used Terms in Grants
Unobligated Balance: The portion of the funds authorized by the Federal agency that has not been obligated by the recipient.
Unliquidated Obligations: Reports prepared on an accrued expenditure basis, the amount of obligations incurred by the recipient for which an outlay has not been recorded.
Definitions of Frequently Used Terms in Grants (Continued)
Prior Approval: Written permission provided by the authorized granting official from the IHS grants and program office before the recipient may undertake certain activities (such as performance or modification of an activity), significant rebudgeting, or exceed a certain dollar level.
Change in Scope: A process, usually initiated by the grantee, whereby the objectives or specific aims identified in the approved grant application are significantly changed.
Goals of Project Monitoring
Assess progress toward meeting the goals and objectives of the project
Determine level and use of Federal resources
Why is it Important to Monitor Progress?
Assess progress in the fieldIdentify potential problemsCreate annual reportsAbility to give an account for the
Federal dollarsJustify budget requestsDetermine future needs in the
program areas
Progress Reporting Requirements
Generally, progress reports are due annually unless otherwise indicated in the NoA.
Format of the progress report is generally included in the NoA.
Financial Reporting Requirements
Reports of expenditures are required as documentation of the grants financial status according to the records of the recipient.
Generally, due annually unless otherwise indicated in the NoA.
Expanded Authorities
Waives certain cost related and other prior approval requirements for the grantee.
Available to all grantees unless otherwise indicated in the NoA.
Expanded Authorities
Pre Award Costs up to (and including) 90 days
One-time no cost extension up to 12 months
All cost-related prior approvals unless the action is considered a change in scope.
Prior Approval Requirements
Alterations and renovationsCapital expendituresAddition of a foreign componentPreaward Costs >90 days prior to
effective date of new or competing awardDeviation from award terms and
conditionsChanges in grantee organizational status
Prior Approval Requirements Transferring of funds between
construction and nonconstruction work Second no-cost extension or extension >
12 months Need for additional NIH funds—aka
supplement Carryover of unobligated balances Change in scope Change in key personnel Change in grantee Institution
Carryover Policy
Special Term of Award for NARCH:
All carryover actions require prior approval from the GMO and Program Official. The request must include be made in writing signed by the authorized organizational official and must include a budget and budget justification for carryover amounts.
Carryover of Large Unobligated Balances
Both Grants Management and ProgramStaff must approve the request.
Both officials will ask the following questionsas they review the request:
Will it benefit the proposed research (goals of the project)?
Does it signify a program expansion? Will the approval generate the need for recurring
costs in future years? Is the project on target considering the amount of
carryover that is available?
Carryover of Unobligated Balances Continued
DGO and Program Staff will check FSR to make sure that the total cost of the request is available.
Grantee should be notified, in writing, from the GMO of the decision within 30 days after receiving the request.
Second No Cost Extension
No additional funds required
Scope of project will not change
Time required to ensure adequate completion of originally approved project
Grantee agrees to update all required assurances
Change of Status of PI and Other Key Personnel
Withdrawal of PI or Key Personnel named in NGA
Absence for period of 3 continuous months
Reduction of effort by 25 or more percent of level approved at award
Approval of Substitute PI/Key Personnel Requires…
Justification for the change
Biographical sketch of proposed individual
Other support for that individual
Budget changes resulting from the proposed change
Change in Scope
Change in specific aims
Change from approved use of human subjects
Shift in emphasis to a different disease area
More Indicators of Change in Scope?
Significant Rebudgeting—i.e., when expenditures in a single direct cost budget category deviate by more than 25% of the current budget year total costs awarded
Transfer of the performance of substantive programmatic work to a third party
Incurrence of patient care costs if not previously approved
Purchase of a unit of equipment >$25,000
Indian Health Service Incentives Policy
Incentive items are allowable costs and may be purchased with IHS grant funds. Incentives may be used to support participants in such activities that include, but are not limited to, health fairs, and fitness programs.
The items purchased by grantees must have a reasonable value, not to exceed $30 each, per activity
Indian Health Service Incentives Policy (Continued)
The incentive funds should be reflected under the “other expenses” category of the budget.
Generally, items that are not considered incentives include, but are not limited to, gifts, cash and/or cash prizes, door prizes, or any type of entertainment (e.g., movie passes).
Policy Link: http://www.ihs.gov/PublicInfo/Publications/IHSManual/Circulars/Circ05/Circ05_06/circ05_06.htm
Reimbursement of Indirect Costs
Necessary part of our grants
Cannot be readily identified with the project
Current rate must be established with the cognizant Federal agency in order to receive indirect costs in the award.
Enforcement Actions
In the event of a grantee’s failure to comply with the terms and conditions of award, IHS may take one or more enforcement actions, depending on the severity and duration of the non-compliance.
Enforcement Actions(continued)
Modification of the Terms of Award:
Include special conditions in the award to identify financial or administrative deficiencies.
Withdraw approval of PI or key personnel if there is basis to conclude that the PI and other key personnel are no longer qualified.
Types of Enforcement Actions
Temporarily withhold grant funds pending correction of the deficiency
Disallow costs
Suspension
Termination
Closeout Requirements
Closeout within 90 days of end date if the grant is not to be extended or awarded through a competing segment.
Documents Required: Final Financial Status Report
Must cover the period of time since the last FSR
submitted No unliquidated obligations Must indicate the unobligated funds
Closeout Requirements(continued)
Documents continued:Final Progress Report
Summary of progress toward the stated aims
List of significant results
List of publications
Data on Human Subjects and Data Sharing
plan, if applicable…
Record Retention and Access Requirements for Records
Financial records, supporting documents,
statistical records and all other records pertinent to an award shall be retained
for aperiod of three years from the date of submission of the final FSR.
When Does the Grantee Need to Contact IHS After the Initial Award?
Continuation progress reports
Required Prior Approvals
Questions
Closeout
Policy Matters?
Contact Michelle G. Bulls for policy-related matters.
Telephone: 301-443-6290
Email: [email protected]