Why is NIH changing the payment method for awards to foreign institutions?
NIH is transitioning to the Payment Management System (PMS) to streamline the payment process and enhance NIHs financial data and financial closeout for foreign awards. Additionally, the change to PMS for payment of foreign awards will align foreign awards with domestic awards and will provide foreign grantees with the ability to request funds electronically.
How do I know if my award was issued under the Streamlined Noncompeting Award Process (SNAP)?
The NoA will specify whether an award is subject to SNAP. Look at Section III – Terms and Conditions. If the award is subject to SNAP, the Section III will include this statement “This grant is subject to Streamlined Noncompeting Award Procedures (SNAP).”
What is a competitive segment?
The initial project period recommended for support (usually up to 5 years) or each extension of a project period resulting from a renewal award. For continuing foreign awards issued in FY2013 (awards issued after October 1, 2012) the competitive segment will become two competitive segments for the purposes of transition to PMS:
one segment begins at the budget period start date of the current competitive segment and ends at budget period end date of the FY2012 award and
one segment begins with the budget period start date of the FY2013 awardand ends with the budget period end date of the current competitive segment.
How do I know the fiscal year (FY) of the funds used to fund my award?
The Fiscal Year is a data field on the Notice of Award (NoA) located in SECTION I – AWARD DATA under the Fiscal Information section. See the following example:
Does this affect payment for foreign fellows?
Foreign fellows will continue to be paid by check or EFT by the NIH Office of Financial Management (OFM). However, this change will affect payment of the institutional allowance for foreign fellowships. Payments made to the foreign institution for institutional allowance will be made through PMS.
What is a type 4 award?
A Type 4 award is a funded extension. For FY2013 (October 1, 2012 through September 30, 2013) NIH will issue all foreign, non-competing continuation awards (Type 5s and Type 8s) as Type 4s. This is a temporary technical solution that enables NIH to separately track obligations and payments for foreign grants which span Federal Fiscal Years 2012 and 2013. This change does not affect the due date or submission process of the progress report.
Is NIH changing the carryover authority for foreign awards?
No, NIH is not changing the carryover authority for foreign awards. NIH is changing the internal accounting systems used for payment of foreign awards, which necessitates that foreign grantees return unobligated balances from previous FYs so those funds can be tracked in the new accounting system of record. The balance returned to NIH will be re-obligated in PMS regardless of the carryover authority for the award. If the award was issued with automatic carryover authority, the grantee may drawdown the carryover funds and obligate as they would now.* If the award was not issued with automatic carryover authority, the grantee may not drawdown or obligate the funds unless a revised NoA reflecting the approved carryover amount has been issued.
*In accordance with existing policy, the GMO will review unobligated balances in excess of 25 percent of the total authorized amount for the budget period and may request additional information from the grantee 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 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, or use a combination of these actions. The GMO’s decision about the disposition of the reported unobligated balance will be reflected in the terms and conditions of the NoA.
Will foreign institutions need to return unobligated balances on continuing awards to NIH via check every year?
No, foreign grantees will need to return the unobligated balances on continuing award from FY12 and earlier (i.e. awards issued prior to October 1, 2012) to accommodate the transition to the new payment system in FY13 only. Unobligated balances for awards issued in FY13 and beyond will be reflected in the PMS.
When completing the FFR for the FY2013 award, how do I reflect the unobligated amount from the previous segment for the new segment?
Whether there is carryover authority or not, in the new project period, the grantee must enter the unobligated amount amount in the field entitled “Unexpended Balance From Prior Project Period” at the top of the FFR (see screen shot below). Failure to return unobligated balances in a timely manner may affect future funding.
My award was not issued under SNAP. Are there any changes to my FFR expenditure data reporting?
Foreign awards not issued under SNAP are still required to submit FFR expenditure data annually. See NIH Grants Policy Statement, http://grants.nih.gov/grants/policy/nihgps_2012/nihgps_2012.pdf, Section 188.8.131.52.2 Financial Expenditure Reports. However, the cumulative amount should only reflect the total for the competitive segment (see question A.3). For FFRs for an FY13 award (Types 1, 2, 4, 7, 9), the cumulative balance on the FFR will begin with the FY13 award. If there was an unobligated balance from the previous award, it must be entered in the field entitled “Unexpended Balance From Prior Project Period” at the top of the FFR.
My award was issued under SNAP. How do I prepare my FFR expenditure data?
See NIH Grants Policy Statement, http://grants.nih.gov/grants/policy/nihgps_2012/nihgps_2012.pdf, Section 184.108.40.206.3 Modified Financial Reporting Requirements. For awards issued under SNAP to foreign institutions after October 1, 2012, foreign grantees are not required to report expenditure data annually via the FFR. For these awards, FFR expenditure data is required only at the end of a competitive segment (see question A.3). If the award was issued as a non-competing continuation award in FY13 (Type 4), the grantee will submit one FFR covering the funding period from the start of the Type 4 award through the end of the competitive segment. If there was an unobligated balance from the previous award, it must be entered in the field entitled “Unexpended Balance From Prior Project Period” at the top of the FFR. If the FY13 award is a new award (Type 1, 2, 9), only one FFR will be submitted for the award at the end of the competitive segment.
For initial awards issued on or after October 1, 2012 (Fiscal Year 2013), when preparing the FFR expenditure data grantees must use the currency rate in effect at the time the funds are drawn down from PMS. For initial awards issued prior to October 1, 2012, grantees must use the currency rate in effect at the time they are preparing the FFR expenditure data.
What if I drawdown funds, but cannot obligate them within three days because I need to complete additional requirements from my country or my institution in order to be able to spend the funds?
This requirement is intended to minimize the time elapsing between the transfer of funds from the Federal government and disbursement by a grantee. Therefore, although the grant may be financed by advance payments, the intent is that grantees draw funds on an as-needed basis—specifically, no more than 3 days before the funds are needed. All Federal funds deposited by PMS in a grantee’s bank account as an unrestricted advance payment should be fully disbursed (checks written, signed, and issued to the payees) by the close of business the next workday after receipt of the funds. If there are constraints on the expenditure of funds, (e.g. your government requires authorization to expend funds from other countries), the funds should be fully disbursed by the close of business the day following availability of funds.
Where do I find more information on PMS registration and training?