The More You Know: PIs or PI Delegates Can Now View Prior Approval No-Cost Extension Requests in eRA Commons

This past October NIH made updates to Commons. These updates now allow principal investigators, as well as their delegates, to view submitted requests for no-cost extensions (i.e., prior approval NCEs). Previously only the signing official (SO) could view the PDF version of this request. To access the request, please select the relevant document from the “Status Information” screen under the “Other Relevant Documents” section. Please note, however, that, as before, only signing officials can initiate, edit, and submit requests for prior approval no-cost extensions. As a reminder, no-cost extension requests should be made no earlier than 90 days before the end of the project period and no later than the project’s end date. For instructions on requesting either a grantee-approved or prior approval NIH no-cost extension, as well as related information on the PI delegation process, please visit OSP’s previous blog posts: No-Cost Extension Requests NIH eRA Commons Account Delegations For any questions or concerns, please contact your OSP specialist.

The More You Know: Prior Approval Through eRA Commons

Did you know that certain prior approval requests can be electronically routed through eRA Commons? Once the PI submits the request via eRACommons, it will be forwarded to the relevant OSP specialist, who will then review and submit to the agency. Applicable requests may include: Withdrawal requests No-Cost extensions (not including first no-cost extensions) Change of PI requests Carryover requests Requests for direct costs over 500k For questions or concerns please contact your OSP specialist.  

Reminder: NIH Policy Regarding Changes to Program Directors, Principal Investigators, or Other Senior/Key Personnel Named in the Notice of Award (NoA)

Please note that prior approval is required any time there is a change in the status of the PD/PI or other senior/key personnel—those individuals named in the NoA—that will impact his or her ability to carry out the approved research at the location of, and on behalf of, VUMC. NIH publishes a non-exhaustive list of changes that may qualify as requiring NIH prior approval: Withdrawal from the project Absence from the project for a continuous period of three months or more Reduction in time devoted to the project by 25% or more from the level approved at the time of the initial competing award Restrictions imposed by the institution, including but not limited to any restrictions on access to the institution or to the institution’s resources, or changes to employment or leave status Any questions regarding the need for prior approval should be directed to the relevant OSP specialist.

The More You Know: Letters of Intent for Applications

Certain FOAs may include a provision requesting or advising that prospective applicants submit a letter of intent prior to application submission. These letters should briefly describe the proposed projects and whether plans touch on special policy areas (human subjects, clinical, or animal research). At minimum a letter of intent should include the following items: Descriptive title of proposed research Name, address, and telephone number of the PI(s) Names of other key personnel Participating institutions Number and title of the funding opportunity Please note that a letter of intent is not required, not binding, and does not enter into the review of an application. Contact information for the addressee can be found on the program announcement. NIH reminds all applicants that budgets in excess of $500,000 (excluding consortium F&A costs) for any year of the project require prior approval from IC programmatic staff no less than six weeks before the anticipated submission date. Applicants should include relevant information regarding the approval in

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User-Submitted Question: Do All Awards Require Prior Approval for Carryforward?

Depending on the type, certain awards may be eligible for carryforward without prior approval. For example, Streamlined Noncompeting Award Procedures (SNAP) awards allow for unobligated balances to be carried over into the next budget period without Grants Management Officer prior approval; however, should the estimated unobligated balance exceed 25 percent of the current year’s total approved budget, grantees are required to provide an explanation (and plans for expenditure) within the RPPR. Please consult Section III of the NGA to determine whether prior approval is required. For questions please contact your OSP specialist.

Process Change: NIH Prior Approval Requirement for Any Application Requesting 500k or More in Direct Costs Within a Single Budget Period

On January 25, 2018, NIH modified its prior approval intake process for any application requesting 500k or more in direct costs (excluding consortium F&A costs) within a single budget period. The revised procedure stipulates that, no less than six weeks before application submission, applicants must contact the assigned Program Officer, who will then either a) grant approval for the request via email or b) issue an invitation for the applicant to submit the request through the prior approval portal in eRA Commons. Please note that the option to submit this request via the Commons portal is only available via invitation and will not appear for the applicant without the involvement of the NIH Program Officer. While individual instructions may vary according to institute, OSP recommends the following items be included within the written prior approval request: Title Anticipated application receipt date Description of specific aims Significance of proposed research Key personnel (including eRA Commons IDs for PI[s] or contact PI)

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Change of Grantee Institution – Outgoing Transfer

NIH prior approval is required for the transfer of the legal and administrative responsibilities of a grant-supported project or activity from one legal entity to another before the expiration date of the approved project period.   Outgoing transfers have three distinct requirements: Relinquishing Statement Final Invention Statement Final Financial Status Report For detailed process guidance, please visit the OSP website.

Salary Supplementation and Compensation on Research Career Development K-Awards

For those departments with K-awards, please make note of the recent NIH notice NOT-OD-17-094: “Clarification and Update: Salary Supplementation and Compensation on Research Career Development K Awards,” released July 24, 2017. This notice makes two significant changes to previous policies: Institutions can now supplement the recipient’s salary with either institutional or non-federal funds up to a level consistent with the institutional salary scale. Though this has been in practice previously, this notice simplifies earlier language and clarifies confusion. The new policy also modifies the prior approval process for those grantees receiving other sponsored funding not directly tied to the K-award—whether federal, non-federal, or institutional. K-award recipients traditionally devote 75% effort to their project. This change applies to how the 25% effort and associated salary not covered by the K-award can be funded. NIH previously required prior approval for additional federal sources not covered by the K-award; however, the new policy stipulates that, provided that the specific aims and effort on

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