Compliance Hot Topic: Changes to Federal Research Terms & Conditions
This content covers recent updates to federal research terms and conditions, including changes in award applicability and the publication of new approval matrices. The updates impact awards made on or after October 1, 2024, with specific details provided for different agencies such as NSF and NIH. The post highlights the importance of staying informed about regulatory changes in post-award fiscal compliance.
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COMPLIANCE HOT TOPIC: POT POURRI MRAM November 2024 Matt Gardner Post Award Fiscal Compliance
Changes to the Federal Research Terms & Conditions (1 of 2) > Research Terms and Conditions page updated to reflect that the RTCs are not applicable to awards made on or after October 1, 2024 This includes the RTC Prior Approval Matrix > Link: https://www.nsf.gov/awards/managing/rtc.jsp MRAM Matt Gardner - PAFC
Changes to the Federal Research Terms & Conditions (2 of 2) > NSF has published the NSF-specific Prior Approval Matrix > The NSF Prior Approval Matrix is applicable to awards made on or after October 1, 2024 This includes sponsor-issued modifications and/or supplemental funding > Link: https://www.nsf.gov/bfa/dias/policy/gc1/priorapprovals/oct24.pdf MRAM Matt Gardner - PAFC
Changes to the RTCs In Summary (1 of 2) The applicable resource is determined by whether the award was issued on or after October 1, 2024 For NSF > Awards issued before October 1, 2024 RTCs: https://www.nsf.gov/awards/managing/rtc.jsp NSF PAPPG (23-1): https://new.nsf.gov/policies/pappg/23-1 > Awards issued on or after October 1, 2024 GC-1: https://www.nsf.gov/bfa/dias/policy/gc1/oct24.pdf NSF Prior Approval Matrix: https://www.nsf.gov/bfa/dias/policy/gc1/priorapprovals/oct24.pdf NSF PAPPG (24-1): https://new.nsf.gov/policies/pappg/24-1 MRAM Matt Gardner - PAFC
Changes to the RTCs In Summary (2 of 2) For HHS/NIH, NASA, USDA/NIFA, Dept. of Commerce, Dept. of Energy, Dept. of Homeland Security: > Awards issued before October 1, 2024 RTCs: https://www.nsf.gov/awards/managing/rtc.jsp Various agency-specific terms and conditions > Awards issued on or after October 1, 2024 Various agency-specific terms and conditions MRAM Matt Gardner - PAFC
NIH Updates Prior Approval Matrix > NIH is working with other Federal research agencies to update and re-publish the prior approval matrix and national policy requirements > No timeline given as to when to expect publication of a new prior approval matrix MRAM Matt Gardner - PAFC
NIH Updates Unilateral Closeout (1 of 2) > Federal regulations require federal agencies to report entities which fail to submit closeout reports within one year of the period of performance end date 2 CFR 200.341 2 CFR 200.344(i) > NIH issued NOT-OD-24-055 last January stating: NIH may initiate unilateral closeout if a recipient does not provide timely, accurate closeout reports or does not respond timely to NIH requests to reconcile discrepancies in grant records. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-24- 055.html MRAM Matt Gardner - PAFC
NIH Updates Unilateral Closeout (2 of 2) > What are closeout reports ? Final Federal Financial Report (FFR) Final Research Performance Progress Report (F-RPPR) Final Invention Statement and Certification (FIS) > All reports are due within 120 days of the end of the period of performance > NIH will initiate unilateral closeout for all awards that fail to meet closeout requirements within one year > NIH actions can include: withholding of further awards, disallowance of costs, or additional corrective actions deemed appropriate MRAM Matt Gardner - PAFC
EFFORT REPORTING / ECC OFFICE HOURS
Upcoming Effort / ECC Focused Topic Office Hour Thursday, November 21st@ 10:00am 11:00am > Scheduled topics: System updates Overview of reporting period dates Impacts of PAAs on grant reporting/closeout process > Final Action Date; award end dates; invoicing and financial reporting requirements > Sessions are recorded and uploaded to the PAFC website (along with any slide decks) https://finance.uw.edu/pafc/session_recordings MRAM Matt Gardner - PAFC
Open Office Hours Every Friday @ 10:AM Friday, November 15th@ 10:00am 11:00am Friday, November 22nd@ 10:00am 11:00am > No set topic; all questions are welcome > Office Hour info and Zoom links: https://finance.uw.edu/pafc/effort-reporting/ecc-office-hours > No Office Hours on November 29th(Thanksgiving) MRAM Matt Gardner - PAFC
Questions > Post Award Fiscal Compliance (PAFC) effortreporting@uw.edu (Effort questions) gcafco@uw.edu (All other compliance questions) https://finance.uw.edu/pafc/ > Matt Gardner mgard4@uw.edu > David Parks, Effort Compliance Analyst parksd2@uw.edu MRAM Matt Gardner PAFC
